State v. Van Dusen

CourtCourt of Appeals of Kansas
DecidedMay 8, 2026
Docket127754
StatusUnpublished

This text of State v. Van Dusen (State v. Van Dusen) is published on Counsel Stack Legal Research, covering Court of Appeals of Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Van Dusen, (kanctapp 2026).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 127,754

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

SHANE CHRISTOPHER VAN DUSEN, Appellant.

MEMORANDUM OPINION

Appeal from Montgomery District Court; F. WILLIAM CULLINS, judge. Submitted without oral argument. Opinion filed May 8, 2026. Reversed and remanded with directions.

Sam Schirer, of Kansas Appellate Defender Office, for appellant.

Andrew J. Lohmann, assistant solicitor general, and Kris W. Kobach, attorney general, for appellee.

Before GARDNER, P.J., ARNOLD-BURGER and SCHROEDER, JJ.

PER CURIAM: Shane Christopher Van Dusen timely appeals his conviction of aggravated interference with parental custody following a bench trial on stipulated facts. On appeal, Van Dusen makes multiple claims the district court erred. Because we find the district court failed to conduct an adequate plea colloquy to obtain a valid waiver of Van Dusen's right to a jury trial, we reverse and remand for a new trial. With this resolution we decline to address the other issues Van Dusen presents on appeals.

1 FACTUAL AND PROCEDURAL BACKGROUND

Van Dusen is a divorced father of two boys. In late 2022, Van Dusen's ex-wife (Mother) had custody of their two sons, ages 17 and 13 years. Although Mother had residential custody, Van Dusen had limited visitation.

Parenting time with Van Dusen did not go as planned. On more than one occasion problems arose with the parenting plan and claimed violations by Van Dusen. We need not go into the details of all of the allegations given the need to reverse this matter based on an inadequate plea colloquy.

The matter was set for a jury trial. The day before trial, Van Dusen waived his jury trial right, and the parties agreed to a bench trial on stipulated facts. Defense counsel explained that the purpose of the bench trial was to preserve multiple issues for appeal. The district court asked if Van Dusen would like to waive his right to a jury trial and submit the case on stipulated facts. Van Dusen said that he did but wanted to add to the facts that he was misdiagnosed with schizophrenia based on information provided by Mother when he went to a mental institution. The district court declined adding to the stipulated facts and asked if Van Dusen still wanted to proceed. Van Dusen agreed if the proceedings would not affect his custody rights, and the district court explained it would enter no orders related to the children. The district court again asked if Van Dusen was ready to proceed, and he agreed.

Van Dusen then stipulated to each element of aggravated interference with parental custody. He also stipulated that the facts, along with all reasonable conclusions and inferences, provided a sufficient factual basis for a conviction under K.S.A. 21- 5409(b)(2)(C), aggravated interference with parental custody. The district court found Van Dusen guilty as charged.

2 At sentencing, Van Dusen requested to withdraw his plea, asserting he wanted to take the case to a jury trial. He claimed he pled "under distress" because a man on the payroll of the cartel threatened to kill him, his sons, and Mother. The district court accepted Van Dusen's characterization of pleading no contest. Nevertheless, the district court told Van Dusen he could seek to withdraw his plea after sentencing if he wanted to and to discuss it with his attorney.

The district court found Van Dusen had no prior convictions; thus, his criminal history score was I with his sentence being 12 months' imprisonment with presumptive probation for 12 months. The district court determined, given the amount of time Van Dusen had already served was longer than his sentence, it would sentence him to time served.

ANALYSIS

Van Dusen argues the district court did not ensure he knowingly and voluntarily waived his right to a jury trial. He argues the brief colloquy engaged in by the court did not fully apprise him of the rights he was waiving by not proceeding to a jury trial. The State argues the record shows Van Dusen clearly understood his jury trial rights, particularly from the fact he was set for a jury trial the next day, and he voluntarily waived his right.

"Generally, issues not raised before the district court cannot be raised on appeal." State v. Gatewood, 321 Kan. 564, 574, 582 P.3d 534 (2026). Van Dusen did not specifically object to the lack of a knowing and intelligent jury trial waiver at his plea hearing. But he did move to withdraw his plea at the sentencing hearing and asked for a jury trial because his plea was not freely and voluntarily made. He asserted that he pled under distress because a man on the payroll of the cartel threatened to kill him, his sons, and Mother. The district court accepted Van Dusen's characterization of pleading no

3 contest. Nevertheless, the district court believed all parties wanted to bring the case to a conclusion and told Van Dusen that if he wanted to withdraw his plea after sentencing, then he could discuss it with his attorney.

We find that Van Dusen sufficiently preserved his challenge to his plea as unknowingly and involuntarily entered based on coercion. And it is important to note that no one disputed his allegation at the sentencing hearing. See also State v. Redick, 307 Kan. 797, 802, 414 P.3d 1207 (2018) ("'[W]hether the court has advised a defendant of his or her right to a jury trial . . . should be one of the last [issues] to be denied the opportunity for exceptional treatment'" under the preservation rule.).

We review the waiver of a jury trial right for substantial competent evidence. And when the facts that support the district court's determination are not in dispute, whether the defendant knowingly and voluntarily waived the right to a jury is solely a legal inquiry subject to unlimited appellate review. State v. Harris, 311 Kan. 371, 375, 461 P.3d 48 (2020).

The Sixth Amendment to the United States Constitution, sections 5 and 10 of the Kansas Constitution Bill of Rights, and Kansas statutes guarantee the right to a jury trial for criminal defendants. Redick, 307 Kan. at 803; see K.S.A. 22-3403(1). The denial of a jury trial right through the failure to obtain a sufficient jury trial waiver before either a bench trial or a guilty plea constitutes structural error. State v. Bentley, 317 Kan. 222, 232, 526 P.3d 1060 (2023).

A defendant's waiver of the fundamental right to a jury trial is "'strictly construed to ensure the defendant has every opportunity to receive a fair and impartial trial by jury.'" Harris, 311 Kan. at 376. District courts cannot accept jury trial waivers "'unless the defendant, after being advised by the court of his right to trial by jury, personally waives his right to trial by jury, either in writing or in open court for the record.'" State v.

4 Johnson, 310 Kan. 909, 919, 453 P.3d 281 (2019). "The choice whether to waive jury trial rests solely with the defendant." Redick, 307 Kan. at 803.

A valid waiver requires the district court to engage directly with the defendant to ensure the defendant understands the rights being waived. For a legally sufficient waiver, the district court must clearly and unequivocally advise the defendant of the right to a jury trial. The defendant then must waive the right freely, voluntarily, and with a full understanding of its implications.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Redick
414 P.3d 1207 (Supreme Court of Kansas, 2018)
State v. Johnson
453 P.3d 281 (Supreme Court of Kansas, 2019)
State v. Harris
461 P.3d 48 (Supreme Court of Kansas, 2020)
State v. Beaman
286 P.3d 876 (Supreme Court of Kansas, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Van Dusen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-van-dusen-kanctapp-2026.