State v. Washington

Court of Appeals of Kansas·Decided July 17, 2026·No. 128557·Unpublished

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 128,557

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

ANTHONY WASHINGTON, Appellant.

MEMORANDUM OPINION

Appeal from Seward District Court; CLINT PETERSON, judge. Submitted without oral argument. Opinion filed July 17, 2026. Affirmed.

Emily Brandt, of Kansas Appellate Defender Office, for appellant.

Russell Hasenbank, county attorney, and Kris W. Kobach, attorney general, for appellee.

Before CLINE, P.J., BOLTON FLEMING, J., and JEFFREY GETTLER, District Judge, assigned.

PER CURIAM: Anthony Washington appeals the revocation of his probation.

FACTS

On January 25, 2024, Washington pled no contest to one count of unlawful possession of a controlled substance, a level 5 drug felony. Because this was a third or subsequent conviction, special rule 26 applied and Washington faced a presumptive prison sentence. On April 25, 2024, the district court granted a downward dispositional

1 departure and placed Washington on probation for 12 months, with an underlying prison sentence of 22 months.

On July 29, 2024, the State moved to revoke Washington's probation, alleging he failed to comply with its terms. Washington denied the allegations, and the district court held an evidentiary hearing on October 31, 2024. The State's case rested on an affidavit prepared by intensive supervision officer (ISO) Astacia Thomson. Although Thomson was subpoenaed, she did not appear. The State instead called Kayla Janko, Director of Cimarron Basin Community Corrections, who testified that Thomson was no longer employed with the agency and that Janko, as the current "keeper of the file," maintained the records in the ordinary course of business. Janko then read Thomson's affidavit into the record, identifying violations that included failing to report contact with law enforcement, failing to timely report to the ISO, failing to attend employment skills classes, failing to verify employment, failing to pay court costs, failing to provide contact information, and failing to pay for or complete a drug and alcohol assessment. The State called no other witnesses, and the affidavit itself was never admitted into evidence.

On cross-examination, Janko acknowledged that Washington had passed all urinalysis tests, attended meetings (albeit late), was employed, and provided pay stubs to the ISO. Washington had also paid some of his fees.

Washington also testified. He explained that he had not reported his contacts with law enforcement because he was not in trouble in either instance. He was homeless, sleeping on couches, in the park, or at a motel. He was working two jobs and had provided pay stubs to Thomson, who he believed to be satisfied with that documentation. He had not paid for the drug and alcohol evaluation because Thomson told him she was going to revoke his probation. Washington added that he knew the evaluation was important and had remained sober.

2 The district court found Washington violated his probation. Because Washington was on probation as a result of a departure sentence, the district court revoked Washington's probation and imposed his underlying prison sentence without modification.

Washington timely appealed.

LEGAL ANALYSIS

Did the district court err in revoking Washington's probation when Washington was not allowed to confront and cross-examine the State's only witness?

Preservation

Washington concedes that his counsel did not object when Janko read Thomson's affidavit into the record, but he asks this panel to review the issue under an exception to the preservation rule on constitutional grounds. The State "believes K.S.A. 60-404 is applicable in this case but also acknowledges the issue in this case implicates the defendant's due process rights."

Appellate courts generally do not address issues raised for the first time on appeal unless an exception applies. One exception is when "'consideration is necessary to serve the ends of justice or to prevent the denial of fundamental rights.'" State v. Allen, 314 Kan. 280, 283, 497 P.3d 566 (2021). Given the importance of Washington's right to confrontation and the fact that the affidavit was the State's only evidence, it would fit within this exception. The issue is properly preserved.

3 Standard of Review

"When determining whether a district court complied with due process requirements in revoking a defendant's probation, we apply an unlimited standard of review." State v. Lyon, 58 Kan. App. 2d 474, 478, 471 P.3d 716 (2020).

A probation revocation has two steps. The district court must first find by a preponderance of the evidence that the probationer violated a condition of probation. Second, it exercises discretion in deciding whether the violation warrants revocation or in selecting another sanction under K.S.A. 22-3716. Lyon, 58 Kan. App. 2d at 478.

Probation is an "act of grace." State v. Hurley, 303 Kan. 575, 581, 363 P.3d 1095 (2016). Once granted, however, the probationer "acquires a conditional liberty interest which is subject to substantive and procedural due process limits on its revocation," and probation cannot be revoked "'unless it is made to appear that the probationer has failed to comply with the conditions of probation.'" 303 Kan. at 581. Revocation proceedings must therefore "comport with minimum due process. A probationer facing revocation must be afforded an opportunity to confront and cross-examine adverse witnesses unless the judge specifically finds good cause for not allowing confrontation." State v. Marquis, 292 Kan. 925, Syl. ¶ 3, 257 P.3d 775 (2011). The Legislature codified these protections in K.S.A. 22-3716(b)(2):

"Unless the defendant, after being apprised of the right to a hearing by the supervising court services or community correctional services officer, waives such hearing, the court shall cause the defendant to be brought before it without unnecessary delay for a hearing on the violation charged. The hearing shall be in open court and the state shall have the burden of establishing the violation. The defendant shall have the right to be represented by counsel and shall be informed by the judge that, if the

4 defendant is financially unable to obtain counsel, an attorney will be appointed to represent the defendant. The defendant shall have the right to present the testimony of witnesses and other evidence on the defendant's behalf. Relevant written statements made under oath may be admitted and considered by the court along with other evidence presented at the hearing."

These statutory safeguards satisfy due process. Hurley, 303 Kan. at 582. When they are not observed, the resulting error is constitutional, and the State must "persuade the reviewing court, beyond a reasonable doubt, that there is no reasonable possibility that the error affected the outcome." 303 Kan. 575, Syl. ¶ 4.

Washington's appeal turns on the confrontation component of this framework.

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Related

State v. Carter
614 P.2d 1007 (Court of Appeals of Kansas, 1980)
State v. Blue
592 P.2d 897 (Supreme Court of Kansas, 1979)
State v. Marquis
257 P.3d 775 (Supreme Court of Kansas, 2011)
State v. Yura
825 P.2d 523 (Supreme Court of Kansas, 1992)
State v. Graham
30 P.3d 310 (Supreme Court of Kansas, 2001)
State v. Hurley
363 P.3d 1095 (Supreme Court of Kansas, 2016)
State v. Clapp
425 P.3d 605 (Supreme Court of Kansas, 2018)
State v. Lyon
471 P.3d 716 (Court of Appeals of Kansas, 2020)
State v. Allen
497 P.3d 566 (Supreme Court of Kansas, 2021)