State v. Wicks

CourtCourt of Appeals of Kansas
DecidedSeptember 19, 2025
Docket127785
StatusUnpublished

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

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 127,785

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

MICHAEL W. WICKS, Appellant.

MEMORANDUM OPINION

Appeal from Douglas District Court; SALLY D. POKORNY, judge. Submitted without oral argument. Opinion filed September 19, 2025. Affirmed.

Kai Tate Mann, of Kansas Appellate Defender Office, for appellant.

Jon Simpson, senior assistant district attorney, Dakota Loomis, district attorney, and Kris W. Kobach, attorney general, for appellee.

Before GARDNER, P.J., COBLE and BOLTON FLEMING, JJ.

PER CURIAM: Michael W. Wicks appeals a single aspect of his sentence after pleading guilty to, and being convicted of, three counts of sexual exploitation of a child. Wicks argues that the imposition of lifetime postrelease supervision—which is mandated by K.S.A. 22-3717(d)(1)(G)(i) for convictions of sexually violent crimes where the offender is 18 or older—required the court to make a judicial finding that he was over 18 years of age in violation of his constitutional rights. Finding Wicks presents no new argument to distinguish his case from others finding against his position, we decline to review his unpreserved claim and affirm his sentence.

1 FACTUAL AND PROCEDURAL BACKGROUND

The State originally charged Wicks with sexual exploitation of a child, an off-grid felony, and aggravated internet trading in child pornography, a severity level 3 person felony. The complaint noted in the description of each offense that Wicks was at least 18 years old. Wicks eventually negotiated a plea agreement in which he offered to plead no contest to an amended complaint charging three counts of sexual exploitation of a child, severity level 5 person felonies. In exchange, the State would dismiss the original charges and permit Wicks to argue for a lesser penalty at sentencing. Although nothing in the written plea agreement noted Wicks' age, he acknowledged in the written notice of duty to register that his birthdate was in 1970 and in the written plea advisory Wicks reported his age as 52.

At the plea hearing, defense counsel stated that Wicks understood he would be subject to lifetime postrelease supervision as the result of the pleas. The district court also confirmed that Wicks understood the offenses carried with them a period of lifetime supervision. When asked for a factual basis for Wicks' no-contest pleas, the State recited a factual basis that did not allege Wicks' age and did not reference the allegations within the amended complaint. Nevertheless, unlike the original complaint, the amended complaint did not allege Wicks' age to be at least 18 years of age.

After reviewing Wicks' understanding of the rights he was waiving by entering guilty pleas, the court accepted Wicks' no-contest pleas and adjudicated him guilty of three counts of sexual exploitation of a child.

Wicks sought a durational sentencing departure, but, at sentencing, the court rejected the request. The court imposed consecutive terms of imprisonment for the three counts, resulting in a controlling prison term of 123 months and ordered the sentences to run consecutive to any remaining sentence imposed in Jefferson County case No. 2019

2 CR 149. The court ordered lifetime postrelease supervision, awarded two days of jail time credit, and waived any costs and fees.

Wicks appeals.

ANALYSIS

Wicks raises a single issue in this appeal, challenging the imposition of lifetime postrelease supervision as a violation of his due process rights as interpreted by Apprendi v. New Jersey, 530 U.S. 466, 490, 120 S. Ct. 2348, 147 L. Ed. 2d 435 (2000). Wicks argues that the district court did not advise him that he had a right to have his age proven to a jury beyond a reasonable doubt, ask him to waive his right to have a jury determine his age beyond a reasonable doubt, or even indicate it was relevant at all.

Legal Principles

The question of whether the district court violated a defendant's constitutional rights as described by Apprendi presents a question of law subject to unlimited review. State v. Huey, 306 Kan. 1005, 1009, 399 P.3d 211 (2017).

The United States Supreme Court's decision in Apprendi outlines that "[o]ther than the fact of a prior conviction, any fact that increases the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury, and proved beyond a reasonable doubt." 530 U.S. at 490; see also State v. Gould, 271 Kan. 394, 405-06, 23 P.3d 801 (2001) (same). This "statutory maximum" as described in Apprendi and the line of cases following is the "maximum sentence a judge may impose solely on the basis of the facts reflected in the jury verdict or admitted by the defendant." Blakely v. Wahington, 542 U.S. 296, 303, 124 S. Ct. 2531, 159 L. Ed. 2d 403 (2004); see State v. Bello, 289 Kan. 191, 199, 211 P.3d 139 (2009).

3 Lifetime postrelease supervision is, both statutorily and as defined by precedent, part of a defendant's sentence. K.S.A. 21-6804(e)(2)(C) ("In presumptive imprisonment cases, the sentencing court shall pronounce the complete sentence which shall include the . . . period of postrelease supervision at the sentencing hearing."); State v. Mossman, 294 Kan. 901, 907-08, 281 P.3d 153 (2012). Because lifetime postrelease supervision is part of a criminal defendant's sentence, "judicial fact-finding which increases a term of postrelease supervision beyond the 'statutory maximum' implicates Apprendi." State v. Nunez, 319 Kan. 351, 355, 554 P.3d 656 (2024) (citing State v. Case, 289 Kan. 457, 458, 213 P.3d 429 [2009]; State v. Anthony, 273 Kan. 726, 728-29, 45 P.3d 852 [2002]). Our Supreme Court has repeatedly "stated that it is immaterial for Apprendi purposes whether the sentence elevating provision is contained within the sentencing statutes or within the elements of the crime itself." Nunez, 319 Kan. at 355 (citing Bello, 289 Kan. at 199).

The parties agree that Wicks' age was not a required element of his convicted crimes—sexual exploitation of a child under K.S.A. 21-5510—and those crimes are classified as sexually violent under K.S.A. 22-3717(d)(5)(H). Standing alone, sexually violent crimes have a 60-month statutory maximum period of postrelease supervision under K.S.A. 22-3717(d)(1)(G)(ii)—unless there is a factual determination made that the defendant was 18 years or older at the time of the crime, in which case the lifetime postrelease supervision period becomes mandatory under K.S.A. 22-3717(d)(1)(G)(i). Nunez, 319 Kan. at 355.

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Related

Apprendi v. New Jersey
530 U.S. 466 (Supreme Court, 2000)
Blakely v. Washington
542 U.S. 296 (Supreme Court, 2004)
State v. Bello
211 P.3d 139 (Supreme Court of Kansas, 2009)
State v. Gould
23 P.3d 801 (Supreme Court of Kansas, 2001)
State v. Case
213 P.3d 429 (Supreme Court of Kansas, 2009)
State v. Anthony
45 P.3d 852 (Supreme Court of Kansas, 2002)
State v. Potts
374 P.3d 639 (Supreme Court of Kansas, 2016)
State v. Mossman
281 P.3d 153 (Supreme Court of Kansas, 2012)
State v. Conkling
540 P.3d 414 (Court of Appeals of Kansas, 2023)
State v. J.L.J.
547 P.3d 501 (Supreme Court of Kansas, 2024)
State v. Nunez
554 P.3d 656 (Supreme Court of Kansas, 2024)
State v. Mendez
559 P.3d 792 (Supreme Court of Kansas, 2024)
State v. Sanders
563 P.3d 234 (Court of Appeals of Kansas, 2025)

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