State v. Vela

CourtCourt of Appeals of Kansas
DecidedAugust 1, 2025
Docket127936
StatusUnpublished

This text of State v. Vela (State v. Vela) 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. Vela, (kanctapp 2025).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 127,936

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

JOSEPH RAUL VELA, Appellant.

MEMORANDUM OPINION

Appeal from Finney District Court; RICHARD MARQUEZ, judge. Submitted without oral argument. Opinion filed August 1, 2025. Affirmed and remanded with directions.

James M. Latta, of Kansas Appellate Defender Office, for appellant.

Jacob T. Gayer, assistant county attorney, Susan Richmeier, county attorney, and Kris W. Kobach, attorney general, for appellee.

Before WARNER, C.J., ATCHESON and ISHERWOOD, JJ.

PER CURIAM: Joseph Vela challenges two aspects of the sentence imposed for his possession-of-methamphetamine conviction. He argues the district court erred by misclassifying a previous out-of-state conviction as a person felony when determining his criminal history, resulting in a longer sentence than Kansas law allowed. He also contends the court erroneously ordered him to pay $686 in restitution to the Finney County Sheriff's Office. After reviewing the record and the parties' arguments, we affirm Vela's sentence but remand for a nunc pro tunc order clarifying that the $686 in question was a permissible court cost, not a restitution award.

1 FACTUAL AND PROCEDURAL BACKGROUND

Vela pleaded guilty to possession of methamphetamine for conduct that occurred in August 2020. In anticipation of Vela's sentencing, the State prepared a presentence- investigation report to summarize Vela's previous convictions and calculate his presumptive sentence under the Kansas Sentencing Guidelines. The report showed that Vela had previously been convicted in Texas of evading arrest, a crime the report classified as a person felony under Kansas law. Based in part on this classification, the report calculated Vela's criminal-history score as B.

Vela objected, arguing that this conviction should have been classified as a nonperson misdemeanor because the Texas statute had no comparable Kansas statute. This dispute remained unresolved, however, because Vela did not appear for sentencing in February 2021, prompting the court to issue a bench warrant. Over the next two years, he was convicted of two new offenses in separate cases.

The district court eventually sentenced Vela in this case in September 2023. At the sentencing hearing, the State moved to amend Vela's criminal-history score to A based on his recent felony convictions. Vela did not object to this amendment. The court determined Vela's criminal-history score was A and, using this score, sentenced Vela to 42 months in prison but suspended this sentence and ordered Vela to serve 24 months of probation.

The court then turned to the question of costs and restitution. After ordering Vela to pay various costs associated with his prosecution, the court asked the State whether it was requesting any restitution. The State responded that the Finney County Sheriff's Office had incurred $686 in costs when transporting Vela to Kansas for the sentencing hearing. The court clarified that its request for restitution was only meant to encompass

2 "victim restitution," and the State acknowledged that it had not filed a restitution request. The court eventually ordered Vela pay $686 "in transportation fees incurred in getting [him] back here for this sentencing hearing."

Despite this exchange at the hearing, the sentencing journal entry told a different tale—stating that Vela was required to pay $686 to the Finney County Sheriff's Office as part of the "Total Restitution" in the case.

Vela's probation was later revoked after he committed new offenses. The court ordered that he serve his underlying 42-month prison sentence. He now appeals, challenging the legality of that sentence.

DISCUSSION

Vela argues that his sentence is legally defective in two ways. He asserts that his Texas conviction for evading arrest should have been classified as a nonperson felony, which would have resulted in a shorter prison sentence. He also argues that we should vacate the district court's order requiring him to pay $686 in restitution to the Finney County Sheriff's Office.

1. The district court correctly classified Vela's Texas conviction for evading arrest as a person felony.

Vela first argues that his sentence is illegal because it was based on what he believes was a misclassification of his Texas conviction for evading arrest, resulting in an incorrect criminal-history score and sentencing range. This argument requires us to interpret and apply the Kansas Sentencing Guidelines—matters over which our review is unlimited. State v. Samuel, 309 Kan. 155, 157, 432 P.3d 666 (2019); see State v. Keel, 302 Kan. 560, 571-72, 357 P.3d 251 (2015).

3 The Guidelines use a combination of a person's criminal history and the severity level of the crime of conviction to determine the presumptive sentencing range for those crimes. See K.S.A. 21-6805 (providing sentencing grid for drug crimes). A person's criminal history for sentencing purposes generally includes any previous felony and misdemeanor convictions, including convictions from other states. See K.S.A. 21- 6810(c), (d); K.S.A. 21-6811(e). These convictions are further classified as "person" or "nonperson" crimes, with person crimes generally resulting in a more severe criminal- history score. See K.S.A. 21-6805.

For over 30 years, Kansas law has defined crimes committed in this state as person or nonperson offenses. But other states do not use this same framework. Thus, courts seeking to classify out-of-state crimes for criminal-history purposes follow two general steps. K.S.A. 21-6811(e)(2)-(3). We first assess whether the crime is a felony or misdemeanor, and then we determine whether Kansas law classifies the out-of-state crime as a person or nonperson offense. K.S.A. 21-6811(e)(2), (3).

Since 2019, Kansas law has classified out-of-state felony convictions as person felonies if any of the circumstances listed in K.S.A. 21-6811(e)(3)(B)(i)-(ii) are present in the elements of the statutes defining those crimes. There is no requirement that the language in the two statutes be identical, only that the out-of-state elements correspond with the nature of the circumstances listed in K.S.A. 21-6811(e)(3)(B)(i)-(ii). State v. Hasbrouck, 62 Kan. App. 2d 50, 53-56, 506 P.3d 924, rev. denied 316 Kan. 761 (2022); see State v. Baker, 58 Kan. App. 2d 735, 745-46, 475 P.3d 24 (2020), rev. denied 312 Kan. 893 (2021).

Two of the circumstances listed in K.S.A. 21-6811

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Related

State v. Weekes
427 P.3d 861 (Supreme Court of Kansas, 2018)
State v. Samuel
432 P.3d 666 (Supreme Court of Kansas, 2019)
State v. Edwards
440 P.3d 557 (Supreme Court of Kansas, 2019)
State v. Baker
475 P.3d 24 (Court of Appeals of Kansas, 2020)
State v. Hasbrouck
506 P.3d 924 (Court of Appeals of Kansas, 2022)
State v. Keel
357 P.3d 251 (Supreme Court of Kansas, 2015)

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State v. Vela, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-vela-kanctapp-2025.