State v. Ward

Court of Appeals of Kansas·Decided August 7, 2026·No. 128179·Unpublished

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 128,179

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS,

Appellee,

v.

CHRISTOPHER MICHAEL WARD, Appellant.

MEMORANDUM OPINION

Appeal from Sedgwick District Court; CHRISTOPHER MAGANA, judge. Submitted without oral argument. Opinion filed August 7, 2026. Affirmed in part, reversed in part, and remanded with directions.

Dylan J. Pryor, of Kansas Appellate Defender Office, for appellant.

Kristi D. Allen, assistant district attorney, Marc Bennett, district attorney, and Kris W. Kobach, attorney general, for appellee.

Before COBLE, P.J., HURST, J., and PAULA HOFAKER, District Judge, assigned.

PER CURIAM: Christopher Michael Ward was convicted of felony theft and ordered to pay restitution to the victim and their insurer. Ward first appeals his conviction of felony theft, arguing the State failed to present sufficient evidence that the value of the stolen property met the requisite minimum value to support the felony level conviction. He also appeals the part of the district court’s restitution order requiring him to pay restitution to an insurance company. Ward claims insurance companies do not experience loss when they pay the claims of insureds. This court agrees with Ward as to his first claim but affirms the district court on his second.

The felony theft conviction is reversed and remanded with directions for the district court to enter a conviction of misdemeanor theft and sentence the defendant accordingly. In all other respects, the district court's judgment is affirmed.

FACTUAL AND PROCEDURAL BACKGROUND

In July 2022, while trying to sell a house in Wichita, the owner noticed something wrong with the air conditioner. According to the owner, the outdoor portion of the air conditioner had been "torn up," in that the coil was removed and the components that housed the coil were scattered on the ground. Due to previous vandalism, the owner had set up a trail camera for security purposes. So, after the incident, the owner reviewed the images taken by the trail camera and provided photographs of a person disassembling the air conditioning unit to law enforcement.

Through its investigation, the Wichita Police Department received an anonymous tip that identified the suspect as Christopher Ward. After receiving the tip, the investigating officer found a photograph and a video from a police incident with Ward that occurred in May 2022 and believed that Ward looked similar to the individual in the trail camera photographs. The officer also searched a database of scrap metal sales to see if Ward sold any scrap metal from the air conditioner unit. He found that Ward's name and driver's license were recorded when he sold metal at a facility in Wichita on July 9, 2022. A receipt showed that Ward sold aluminum copper radiator scrap, copper #1, and copper #2, on July 9, 2022, at around 12:40 p.m. to the facility. Later, the officer met Ward in person to compare his appearance to that of the person on the trail camera. Based on the totality of the circumstances, the officer believed there was probable cause to conclude that Ward was involved in the incident.

The State charged Ward with felony theft of property valued between $1,500 and $25,000 under K.S.A. 21-5801(a)(1)(b)(3) based on the theft of the air conditioner parts.

The case proceeded to a jury trial, and on May 29, 2024, the jury found Ward guilty of felony theft. At sentencing, Ward admitted to his criminal history which included 45 prior convictions, including 21 convictions for theft and 15 convictions for burglary. The district court found that Special Rule 29, a rule concerning a defendant with a history of 3 or more prior thefts, applied.

In support of the motion for a dispositional departure, Ward's attorney asserted that Ward "took responsibility today and did not want to contest the restitution, even though it's quite a large amount, because he does want to get that paid off." Ward also told the district court that he planned to pay the restitution and that he had a job. He promised that if the court gave him the opportunity through a sentencing departure, he would maintain employment and make monthly payments to the restitution.

The district court denied Ward's request for a departure, stating that Ward was a "serial thief and a serial burglar." The court sentenced Ward to 17 months in prison for the theft conviction, subject to 12 months postrelease supervision. The court ordered restitution—"as requested by the State and not objected to by the defense"—of $5,000 and $5,298, respectively, to the victim and the insurance company.

Ward timely appealed.

DISCUSSION

On appeal, Ward first argues there was insufficient evidence to prove felony theft.

Specifically, he asserts that the State failed to present evidence of the fair market value of the stolen property. In his second claim, Ward argues the district court erred in ordering him to pay restitution to an insurer.

I. INSUFFICIENT EVIDENCE OF FELONY THEFT

When reviewing a claim that the State presented insufficient evidence to support a conviction, this court looks to the evidence in the most favorable light to the State to determine "whether a rational fact-finder could have found the defendant guilty beyond a reasonable doubt." State v. Mendez, 319 Kan. 718, 723, 559 P.3d 792 (2024). Ward was convicted of felony theft, defined as "[o]btaining or exerting unauthorized control over property or services" when "done with [the] intent to permanently deprive the owner of the possession, use or benefit of the owner's property or services." K.S.A 21-5801(a)(1). The classification and severity level of a theft conviction is established by the minimum value of the taken property. Ward was convicted of a level 9 nonperson felony which was defined as "[t]heft of . . . property or services of the value of at least $1,500 but less than $25,000." K.S.A. 21-5801(b)(3).

The statute defines the value of the taken property as "the value of the property,"

and the Kansas Supreme Court has explained that "[t]he value to be used in determining whether theft is a felony or misdemeanor is the fair market value of the property." State v. Owens, 248 Kan. 273, 285, 807 P.2d 101 (1991); see also K.S.A. 21-5801(c)(5).

Ward asserts that none of the witnesses at trial testified about the value or fair market value of the stolen property—that is the air conditioner coil and some copper— and that none of the State's exhibits showed its fair market value. In response, the State appears to argue that the value should be determined by the replacement cost because Ward’s theft left the air conditioner nonfunctional. While that statement seems logical, the State provides no legal authority supporting that contention, and the argument is inconsistent with the elements of the crime charged.

At trial, the owner testified that the coil was removed from his air conditioner and that the components that would house the coil were knocked onto the ground. The owner

testified that an HVAC repair company estimated the cost to repair the air conditioner to be about $10,800. The owner then explained the options for repairing the unit, which included replacing just the outdoor unit, which he said would have been "extremely expensive," or replacing both the indoor and outdoor portions of the air conditioner. According to the owner, the downside to just replacing the outside portion of the unit was that it would not come with a warranty. Therefore, the owner replaced both the outside and inside unit so that it would have a warranty for the new homeowner.

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

State v. Ward, (kanctapp 2026).

State v. Ward (State v. Ward) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Baylor v. Commonwealth
683 S.E.2d 843 (Court of Appeals of Virginia, 2009)
State v. Allen
917 P.2d 848 (Supreme Court of Kansas, 1996)
State v. Moss
557 P.2d 1292 (Supreme Court of Kansas, 1976)
State v. Piland
538 P.2d 666 (Supreme Court of Kansas, 1975)
State v. Robinson
608 P.2d 1014 (Court of Appeals of Kansas, 1980)
State v. Stephens
953 P.2d 1373 (Supreme Court of Kansas, 1998)
State v. Owens
807 P.2d 101 (Supreme Court of Kansas, 1991)
State v. Hand
257 P.3d 780 (Court of Appeals of Kansas, 2011)
State v. Watson
186 P.3d 812 (Court of Appeals of Kansas, 2008)
State v. Beechum
833 P.2d 988 (Supreme Court of Kansas, 1992)
State v. Robison
469 P.3d 83 (Court of Appeals of Kansas, 2020)
State v. Allen
497 P.3d 566 (Supreme Court of Kansas, 2021)
State v. Hand
304 P.3d 1234 (Supreme Court of Kansas, 2013)
State v. Charles
318 P.3d 997 (Supreme Court of Kansas, 2014)
State v. Union
553 P.3d 320 (Supreme Court of Kansas, 2024)
State v. Mendez
559 P.3d 792 (Supreme Court of Kansas, 2024)