Kan. Stat. Ann. § 22-3504

Section 22-3504(b) does not permit correction of a jail-credit award as a clerical mistake without a factual basis for clerical error.

State v. Ward · filed 2023-11-09(b)

The weight of Ward's argument cuts against his suggestion that the district court's action of assigning jail credit was a "[c]lerical mistake" that permits correction at any time under K.S.A. 22-3504(b). ... Like the defendant in Smith, Ward makes no attempt to allege a factual basis supporting his allegation of clerical error. Thus, his clerical error argument lacks factual support in the record.

Section 22-3504(b) permits correction of clerical mistakes in a sentencing journal entry, but no correction is needed when the entry conforms to the court’s oral pronouncement.

State v. Wilson · filed 2024-07-05(b)

Here, we find no clerical mistake that needs to be corrected. This is because the journal entry filed by the district court conforms with the orders entered at the sentencing hearing.

Section 22-3504(b) allows a court to correct a clerical error in a sentencing journal entry at any time so the entry reflects the sentence pronounced from the bench.

State v. Sandfort · filed 2025-02-14(b)

The court may correct clerical errors such as this at any time. K.S.A. 22-3504(b). Thus, we remand with directions for the district court to correct the journal entry to properly reflect Sandfort's modified sentence of 15 months' imprisonment, less credit for time served.

Section 22-3504(2) permits a court to correct an incorrect statute number in a journal entry by nunc pro tunc order only when the error is clerical or arithmetic and arose from oversight or omission.

State v. Fulcher · filed 2024-11-01(2)

But as the statute directs, a court should use nunc pro tunc orders only to correct arithmetic or clerical errors, including "incorrect statute numbers" in a journal entry that arise from an oversight or omission.

Section 22-3504(b) permits a nunc pro tunc order to correct clerical errors, but not an error of law in a probation revocation ruling.

State v. McRoberts · filed 2025-03-28(b)

But the State fails to show any arithmetic or clerical errors or that any errors arose from oversight or omission. And "[i]f there is no arithmetic or clerical error arising from oversight or omission, a nunc pro tunc order is not appropriate." 317 Kan. 111, Syl.; see K.S.A. 22-3504(b) (permitting nunc pro tunc order to correct clerical errors). The district court did not make an arithmetic or clerical error on the journal entry by stating that it was revoking because McRoberts had had a "quick dip." Rather, it based that ruling on an error of law and failed to apply the proper legal standard when revoking McRoberts' probation. This is an error of law not properly corrected by a nunc pro tunc order.

Section 22-3504(b) permits a nunc pro tunc order to correct a clerical or scrivener’s error in a journal entry.

State v. Cochran · filed 2025-04-18(b)

A nunc pro tunc order is used only to correct what amounts to a clerical or scrivener's error.

Section 22-3504(b) permits correction by an order nunc pro tunc when a sentencing journal entry contains a clerical error that conflicts with the sentence pronounced from the bench.

State v. Exon · filed 2026-04-17(b)

The appropriate remedy for such a discrepancy between the oral pronouncement of sentence and the journal entry is correction through an order nunc pro tunc. See Johnson, 320 Kan. 246, Syl.; K.S.A. 22-3504(b).

Section 22-3504(b) permits correction at any time of a sentencing journal entry that differs from the judge's oral pronouncement.

State v. Scott · filed 2026-05-29(b)

"During sentencing, the judge's oral pronouncement is controlling, not the journal entry." State v. Edwards, 309 Kan. 830, 835, 440 P.3d 557 (2019). Accordingly, "any journal entry variance from a judge's oral pronouncement during sentencing is a clerical error that may be corrected at any time." 309 Kan. at 835; see also K.S.A. 22-3504(b).

Section 22-3504(b) permits correction of a clerical error in a journal entry that imposes a fee the sentencing court orally waived.

State v. Wood · filed 2026-06-26(b)

As a result, we direct the district court to correct the clerical error in the journal entry to remove the BIDS application fee. See K.S.A. 22-3504(b).

Section 22-3504(b) permits nunc pro tunc correction of clerical errors, but does not permit a substantive challenge to whether the defendant’s conduct satisfied the elements of a crime.

State v. Evans · filed 2026-04-24(b)

In addition, Evans also briefly argues that his actions did not satisfy the elements of human trafficking. But this is a claim of substantive error, rather than an assertion of a clerical error correctable by a nunc pro tunc order under K.S.A. 22-3504(b).

Section 22-3504(2) permits correction of a clerical error in a charging document at any time, including after a guilty finding.

State v. Loeffler · filed 2018-07-27(2)

Thus, under K.S.A. 2017 Supp. 22- 3504(2), the State was allowed to correct the clerical error at any time, even after the trial court made a guilty finding.

Section 22-3504(2) allows a court to correct a clerical error in a sentencing journal entry at any time when the entry differs from the sentence pronounced in court.

State v. Edwards · filed 2019-05-10(2)

Thus, any journal entry variance from a judge's oral pronouncement during sentencing is a clerical error that may be corrected at any time.

Section 22-3504(2) permits a court to correct a clerical mistake in a journal entry at any time by a nunc pro tunc order.

State v. Ortega-Cadelan · filed 2019-08-30(2)

A journal entry may be corrected "at any time" by a nunc pro tunc order. See K.S.A. 2018 Supp. 22-3504(2). ... Because the record reflects that the district court clearly granted the State's motion to amend the severity level to an off-grid felony, we remand this matter with directions for the district court to correct the Journal Entry of Judgment.

Section 22-3504(2) permits a court to correct clerical mistakes in a sentencing journal entry at any time so the entry accurately reflects the crime of conviction.

State v. Moore · filed 2019-10-18(2)

Because the district court's order nunc pro tunc does not clearly or accurately represent the crime of conviction in count 4, we must remand this matter for the district court to enter a second order nunc pro tunc in compliance with the above directions. See K.S.A. 2018 Supp. 22-3504(2) (clerical mistakes may be corrected by the court at any time).

Section 22-3504(2) permits correction at any time of a clerical error in a journal entry, including a reason for revocation the court did not use.

State v. Chavez · filed 2019-11-27(2)

Thus, the reference in the journal entry to public safety and offender welfare appears to be a clerical error. We consider this to be an error in the record arising from oversight or omission that may be corrected at any time. See K.S.A. 2018 Supp. 22-3504(2) (providing for correction of clerical errors in journal entries); State v. Mason, 294 Kan. 675, 677, 279 P.3d 707 (2012) (journal entry that imposes sentence at variance with sentence pronounced from bench is erroneous and must be corrected). Accordingly, we remand to the district court with directions to correct the journal entry of judgment by removing reference to public safety or offender welfare as a reason for revocation.

Section 22-3504(2) permits correction of a clerical mistake in a judgment at any time, including a journal entry that misstates the sentences pronounced in court.

State v. Claude · filed 2020-08-21(2)

The journal entry of judgment must be corrected to reflect concurrent sentences. See K.S.A. 2018 Supp. 22-3504(2) (clerical mistakes in judgments may be corrected at any time).

Section 22-3504(b) allows a district court to correct a clerical error in a sentencing journal entry at any time when the correction reflects the sentence pronounced in court.

State v. Goodridge · filed 2020-10-30(b)

In summary, a clerical error in a journal entry does not alter the sentence pronounced from the bench, nor is a district court bound by such an error. To the contrary, K.S.A. 2019 Supp. 22-3504(b) allows district courts to correct such an error at any time.

Section 22-3504(b) does not allow a nunc pro tunc order to correct a nonclerical criminal history error.

State v. Spears · filed 2021-09-24(b)

And even assuming that a nunc pro tunc order may sometimes constitute appropriate sentencing "relief," we cannot order the district court to correct a sentence nunc pro tunc for a nonclerical criminal history error.

Section 22-3504(b) permits correction of minor clerical errors at any time, but does not permit recalculation of restitution.

State v. Zink · filed 2021-12-30(b)

Under K.S.A. 2020 Supp. 22-3504(b), "[c]lerical mistakes in judgments, orders or other parts of the record and errors in the record arising from oversight or omission may be corrected by the court at any time and after such notice, if any, as the court orders." But the statute is intended to be used to correct "minor clerical errors." State v. Sheets, 60 Kan. App. 2d 378, 379, 494 P.3d 168 (2021). This alleged error cannot be described as a minor clerical error when Zink is asking this court to recalculate his restitution payment, as opposed to something like correcting a transposed number.

Section 22-3504(b) permits a court to correct clerical mistakes in orders at any time, even without an objection below.

State v. Beeson · filed 2022-03-25(b)

Although Beeson did not object at the trial court, K.S.A. 2020 Supp. 22-3504(b) permits us to correct clerical mistakes in orders at any time.

Section 22-3504(b) permits courts to correct clerical mistakes in the record at any time, including errors in a journal entry through a nunc pro tunc order.

State v. Busch · filed 2022-07-22(b)

Under K.S.A. 2021 Supp. 22-3504(b), courts may correct clerical mistakes in the record "arising from oversight or omission" at any time. When a mistake appears on a journal entry, a nunc pro tunc order is the proper remedy. ... To that end, the journal entry should reflect that the court revoked Busch's probation because he violated its terms and conditions, not because he absconded. It should also note that he originally received probation as the product of a dispositional departure.

Section 22-3504(b) allows a court to correct clerical errors in a sentencing journal entry at any time through a nunc pro tunc entry.

State v. Baughman · filed 2022-10-28(b)

"Clerical mistakes in judgments, orders or other parts of the record and errors in the record arising from oversight or omission may be corrected by the court at any time and after such notice, if any, as the court orders." K.S.A. 2021 Supp. 22-3504(b). ... For these reasons, we must remand Baughman's case to the district court with instructions to issue a nunc pro tunc journal entry noting the assessment but waiver of the $100 BIDS application fee and the proper statutory subsection that is the basis for Baughman's convictions of Count 1 and Count 3.

Section 22-3504(b) permits correction of arithmetic or clerical errors in a journal entry of judgment, but does not permit an attack on the underlying convictions.

State v. Edmond · filed 2024-03-22(b)

Edmond provides no authority holding that a defendant can use K.S.A. 2022 Supp. 22-3504(b)—which merely allows for correction of arithmetic or clerical errors in a journal entry of judgment—to attack his convictions.

Section 22-3504(b) permits a journal entry of judgment to be corrected at any time by a nunc pro tunc order for a clerical error arising from oversight or omission.

State v. Caldwell · filed 2022-11-23(b)

A journal entry of judgment may be corrected at any time by a nunc pro tunc order, which is appropriate for correcting clerical errors arising from oversight or omission. See K.S.A. 2021 Supp. 22-3504(b); Potts, 304 Kan. at 708.

Section 22-3504(c)(1) treats a sentence that fails to conform to applicable statutory provisions as illegal, including one that omits oral pronouncement of mandatory postrelease supervision.

Martinez v. State · filed 2021-09-03(c)(1)

A sentence is illegal if, among other reasons, it is imposed by a court lacking jurisdiction or fails to conform to the applicable statutory provisions. K.S.A. 2020 Supp. 22-3504(c)(1). When the district court failed to pronounce a term of postrelease supervision from the bench at sentencing, the resulting sentence did not comply with K.S.A. 2020 Supp. 21-6804(e)(2)(C) and K.S.A. 2020 Supp. 22-3424(a).

Section 22-3504(1) permits correction of an illegal postrelease supervision term carried into later journal entries when the court did not modify that term upon revoking probation.

State v. Dodd · filed 2016-11-10(1)

However, an illegal sentence can be corrected at any time. K.S.A. 22-3504(1). ... The district court never modified Dodd's postrelease supervision term at the probation revocation hearing. Therefore, the postrelease portion of Dodd's sentence remained illegal and the district court did not err in granting the State's motion to correct illegal sentence.

Section 22-3504(1) authorizes a court to correct a sentence that fails to conform to the applicable statutory postrelease supervision term.

State v. Kness · filed 2017-04-07(1)

If it did not conform, then, by virtue of K.S.A. 22-3504(1), the court had authority to correct the sentence. ... The original postrelease supervision term of 36 months did not comport with the law and was an illegal sentence. See Moncla, 301 Kan. at 551. The district court did not err in correcting the illegal sentence and imposing lifetime postrelease supervision.

Section 22-3504(1) allows a court to correct a postrelease supervision term that does not conform to the applicable sentencing statute.

State v. Peterson · filed 2017-08-04(1)

Under K.S.A. 22-3504(1), an illegal sentence is a sentence imposed by a court without jurisdiction; a sentence that does not conform to the applicable statutory provision, either in character or term of authorized punishment; or a sentence that is ambiguous with respect to the time and manner in which it is to be served. ... Peterson's 60-month term of postrelease supervision was illegal, and the district court had the authority to correct it.

Section 22-3504(1) permits a district court to correct a sentence whose postrelease supervision term does not match the term required by statute.

State v. Bradley · filed 2016-06-10(1)

Because Bradley's original sentence did not include the statutorily mandated term of lifetime postrelease supervision, the sentence was illegal and the district court had jurisdiction to correct the illegal sentence by imposing lifetime postrelease supervision.

Section 22-3504 permits a district court to correct an illegal postrelease supervision term and impose the statutorily required term.

State v. Ballard · filed 2009-11-06(1)

Because Ballard’s initial sentence of 36 months’ postrelease supervision was based on the wrong statute, 22-3717(d)(l)(A), the district court had jurisdiction to correct the illegal sentence and impose the legal one under 22-3717(d)(l)(G).

Section 22-3504(1) does not permit a motion to correct an illegal sentence to challenge the constitutionality of lifetime postrelease supervision.

State v. Proctor · filed 2012-07-06(1)

Proctor could not attack the constitutionality of the lifetime post-release supervision in a motion to correct an illegal sentence under K.S.A. 22-3504(1), which may be filed “at any time.”

A sentence omitting a statutorily required term of postrelease supervision is an illegal sentence that may be corrected under § 22-3504.

State v. Garland · filed 2017-03-03

In this case, we find the 24-month term of postrelease supervision originally imposed by the sentencing court did not conform to applicable statutory provisions, which makes it illegal.

Section 22-3504 permits a court to vacate an unauthorized lifetime postrelease-supervision term as part of an illegal sentence.

Williams v. State · filed 2020-10-09(a)

"The court may correct an illegal sentence at any time while the defendant is serving such sentence." ... "A sentence is illegal under K.S.A. 22-3504 when: (1) it is imposed by a court without jurisdiction; (2) it does not conform to the applicable statutory provisions, either in character or punishment; or (3) it is ambiguous with respect to the time and manner in which it is to be served." ... Because the sentencing court erred in imposing lifetime postrelease supervision, that portion of Williams' sentence must be vacated.

Section 22-3504(a) permits correction while the defendant remains on postrelease supervision, even after completing the prison portion of the sentence.

State v. Smith · filed 2024-09-20(a)

The district court retained jurisdiction to resentence Smith because he had not yet completed his total sentence—which included his period of postrelease supervision.

Section 22-3504(1) permits correction of an illegal sentence after probation revocation when the court reimposes the original illegal sentence rather than a lawful lesser sentence.

State v. Reed · filed 2014-10-31(1)

The district court then reimposed an illegal sentence rather than imposing a lesser one at the probation revocation hearing. A revocation of probation may lead to the imposition of a lesser sentence. However, the new sentence cannot be illegal. Thus, the district court had jurisdiction later to correct Reed’s illegal sentence under K.S.A. 22-3504(1), and the district court did not err in doing so.

Section 22-3504(1) does not allow a challenge to probation revocation as an illegal-sentence claim when the underlying sentence itself is not challenged.

State v. Mastrangelo · filed 2015-12-11(1)

An illegal sentence, as contemplated by K.S.A. 22-3504(1), is a sentence imposed by a court without jurisdiction; a sentence that does not conform to the statutory provision, either in the character or the term of authorized punishment; or a sentence that is ambiguous with respect to the time and manner in which it is to be served. ... Mastrangelo is not actually challenging the legality of his underlying sentence. Rather, he is objecting to the revocation of his probation, which would not fall within the Supreme Court's definition of a sentence.

Section 22-3504(1) allows correction of an illegal original sentence after probation revocation when the judge orders the defendant to serve that sentence rather than pronouncing a new one.

State v. Sandoval (Court of Appeals) · filed 2016-02-19(1)

If the judge instead requires the defendant to serve the original sentence, any original illegality continues to exist and is subject to challenge or correction under K.S.A. 22-3504(1).

Section 22-3504(1) does not treat failure to comply with the probation revocation statute as an illegal sentence because that statute does not define a crime or assign a category of punishment.

State v. Brown · filed 2016-08-12(1)

As such, the district court's failure to comply with K.S.A. 2015 Supp. 22-3716, which does not define a crime or assign the categories of punishment to be imposed, does not constitute an illegal sentence.

Section 22-3504(1) does not permit correction of an illegality in an original sentence after a judge pronounces a new sentence following probation revocation.

State v. Roth (Court of Appeals) · filed 2016-07-08(1)

If a new sentence is pronounced from the bench, the original illegality no longer exists, and the new sentence is not subject to challenge or correction under K.S.A. 22-3504(1).

Section 22-3504(1) does not treat alleged irregularities in probation revocation as an illegal sentence when the underlying sentence is lawful.

State v. Kendrick · filed 2017-09-01(1)

But the claimed irregularities in the probation revocation would not result in an illegal sentence within the purview of K.S.A. 22-3504(1).

An illegal component of the original sentence remains correctable under § 22-3504(1) after probation revocation if the judge requires the defendant to serve that sentence rather than sentencing anew.

State v. Sandoval · filed 2018-08-31(1)

If the judge instead requires the defendant to serve the original sentence, any original illegality continues to exist and is subject to challenge or correction under K.S.A. 22-3504(1).

Section 22-3504(1) permits correction of an illegal original sentence after probation revocation if the judge requires that sentence to be served, but not if the judge pronounces a new sentence.

State v. Roth · filed 2018-08-31(1)

If a new sentence is pronounced from the bench, the original illegality no longer exists, and the new sentence is not subject to challenge or correction under K.S.A. 22-3504(1). If the judge instead requires the defendant to serve the original sentence, the opposite is true. Any original illegality continues to exist and is subject to challenge or correction under K.S.A. 22-3504(1).

Section 22-3504(1) permits later correction of an illegal postrelease supervision term imposed after probation revocation when the term does not conform to statutory requirements.

State v. Brook · filed 2019-05-10(1)

It was illegal because it did not conform to applicable statutory requirements; it was therefore subject to later correction under K.S.A. 22-3504(1).

Section 22-3504 does not permit a motion to correct an illegal sentence to challenge a probation revocation, because revocation is not a sentence.

State v. King · filed 2021-03-19(c)(1)

We do not reach the merits of this argument, however, because a district court's decision revoking probation is not a sentence. K.S.A. 2020 Supp. 22-3504 does not authorize courts to address every potential statutory violation, but only those that result in illegal sentences.

The authority to correct an illegal sentence survives probation revocation when the original underlying sentence remains in force.

State v. Ortiz · filed 2019-03-15

Under Sandoval, the authority to correct an illegal sentence survived Ortiz' probation revocation sentence, and the correction did not conflict with the "lesser sentence" requirement under K.S.A. 2011 Supp. 22-3716(b).

Section 22-3504 permits an appellate court to consider an illegal sentence for the first time on appeal even when no motion to correct the sentence was filed.

State v. Hilt · filed 2017-12-15(1)

Although Hilt has not filed a motion to correct illegal sentence, this court has statutory authority to consider an illegal sentence for the first time on appeal.

A challenge to the classification of a prior conviction in a criminal history score may be considered as an illegal-sentence claim for the first time on appeal.

State v. McCloud · filed 2018-02-02(1)

McCloud acknowledges that he did not object to the district court's calculation of his criminal history score of C at sentencing, but he correctly asserts that we may consider a challenge to the classification of a prior conviction in a criminal history score as constituting an illegal sentence for the first time on appeal. See K.S.A. 22-3504(1); State v. Dickey, 305 Kan. 217, 220, 380 P.3d 230 (2016).

Section 22-3504(1) allows a defendant to challenge an illegal sentence based on an incorrect criminal history score for the first time on appeal.

State v. Kelley · filed 2018-03-16(1)

Although defendants are generally prohibited from raising issues for the first time on appeal, a defendant may challenge an illegal sentence at any time. K.S.A. 22-3504(1). Challenges to illegal sentences include challenges to a defendant's criminal history score. A defendant's sentence hinges on the defendant's criminal history, so if the criminal history score is wrong, then the sentence does not comply with Kansas' sentencing statutes and is illegal. State v. Dickey, 301 Kan. 1018, 1034, 350 P.3d 1054 (2015); State v. Moore, 52 Kan. App. 2d 799, 802-03, 377 P.3d 1162 (2016). Accordingly, Kelley is not barred from challenging his criminal history score for the first time on appeal.

A motion to correct an illegal sentence must be filed in the defendant’s criminal case in the sentencing court.

Ali v. Cline · filed 2017-10-06(1)

A motion to correct an illegal sentence is a motion to be filed in a defendant's criminal case. ... Case 92CR2631 was prosecuted in the Shawnee County District Court; therefore, only the Shawnee County District Court has the jurisdiction to consider Ali's illegal sentence claims arising under this case.

Section 22-3504(1) permits a defendant to challenge an illegal sentence based on an incorrectly classified prior conviction for the first time on appeal, even without an objection at sentencing.

State v. Wren · filed 2015-12-18(1)

Here, Wren's failure to object to how his 1988 juvenile felony burglary was classified is not fatal to his appeal; Dickey clearly states an illegal sentence may be corrected at any time and for the first time on appeal.

Section 22-3504(1) permits a legal challenge to the criminal history classification of a prior conviction for the first time on appeal.

State v. Briggs · filed 2016-01-15(1)

It is not an impediment to our consideration of this issue that Briggs raises it for the first time on appeal. In Dickey, our Supreme Court determined that K.S.A. 22-3504(1) authorizes a legal challenge to the criminal history classification of a prior conviction for the first time on appeal.

Section 22-3504(1) permits a legal challenge to the classification of a prior adjudication that affects the criminal history score to be raised for the first time on appeal.

State v. Fisher · filed 2016-01-22(1)

Although Fisher did not challenge the person classification of the prior burglaries in the district court, he may do so for the first time on appeal. In State v. Dickey, 301 Kan. 1018, 1034, 350 P.3d 1054 (2015), our Supreme Court held that "a legal challenge to the classification of a prior adjudication for purposes of lowering [one's] criminal history score[]can be raised for the first time on appeal pursuant to K.S.A. 22-3504(1)."

Section 22-3504(1) allows an illegal sentence claim to be raised for the first time on appeal.

State v. Vanhoozier · filed 2016-01-29(1)

And an illegal sentence claim may be raised for the first time on appeal. See K.S.A. 22-3504(1); State v. Kelly, 298 Kan. 965, 975-76, 318 P.3d 987 (2014).

Section 22-3504(1) allows a defendant to challenge an illegal sentence on appeal even if the issue was not raised at sentencing.

State v. Winn · filed 2016-03-25(1)

Although Winn did not raise this issue at his sentencing, we will consider it because it is essentially a challenge to an illegal sentence under K.S.A. 22-3504(1).

Section 22-3504(1) permits correction of an illegal sentence on direct appeal even when the sentence was not challenged in the district court.

State v. Steffens · filed 2016-04-29(1)

However, K.S.A. 22-3504(1) grants courts the authority to correct illegal sentences at any time, including on direct appeal where the sentence was not challenged below.

Section 22-3504(1) permits a legal challenge to the classification of a prior conviction for criminal history scoring to be raised for the first time on appeal to seek correction of an illegal sentence.

State v. Ohrt · filed 2016-07-15(1)

As he asserts, however, he may raise a legal challenge to the classification of a prior conviction for the purposes of lowering his criminal history score for the first time on appeal under K.S.A. 22-3504(1), which authorizes courts to correct an illegal sentence at any time.

Section 22-3504 cannot be used to challenge a restitution award for the first time on appeal when the award is authorized in character and term.

State v. Williams · filed 2017-01-13(1)

A restitution award of $29.70 is of a character and term permitted under Kansas law. Accordingly, Williams cannot invoke K.S.A. 22-3504 as a way to circumvent his failure to dispute a portion of the restitution order in the district court.

Section 22-3504(1) permits a later challenge to a prior conviction's criminal history classification despite the defendant's failure to object at sentencing.

State v. Marsh · filed 2016-12-02(1)

Therefore, a defendant's failure to object to a classification of his criminal history does not bar a subsequent objection to, or act as a stipulation to, the classification of convictions listed in the defendant's criminal history.

Section 22-3504(1) permits a defendant to challenge the classification of a prior conviction or the resulting criminal history score for the first time on appeal.

State v. Ventris · filed 2017-06-02(1)

Contrary to the State's contention, under K.S.A. 22-3504(1), a defendant may challenge for the first time on appeal the classification of his or her prior conviction and/or the resulting criminal history score used to sentence him or her under the revised Kansas Sentencing Guidelines Act.

Section 22-3504(1) allows a defendant to challenge a sentence as illegal for the first time on appeal.

State v. McVey · filed 2017-08-04(1)

However, K.S.A. 22-3504(1) provides that the "court may correct an illegal sentence at any time." As a result of this statutory mandate, a defendant may challenge a sentence as illegal even for the first time on appeal.

Section 22-3504 gives courts jurisdiction to consider a motion to correct an illegal sentence even when the motion fails to establish that the sentence is illegal.

State v. Edwards · filed 2017-06-02

We hold that the lower courts had jurisdiction to hear and consider Edwards' motion as a motion to correct an illegal sentence made pursuant to K.S.A. 22-3504. But that motion advanced no meritorious argument demonstrating Edwards' sentence was illegal, so the claims fail on the merits.

Section 22-3504 gives courts jurisdiction to hear motions to correct illegal sentences even when the motions fail on the merits.

State v. Askew · filed 2017-06-02

We hold that the lower courts had jurisdiction to hear and consider defendants' motions as motions to correct illegal sentences made pursuant to K.S.A. 22-3504. But the motions advanced no meritorious arguments demonstrating the challenged sentences were illegal, so the claims fail on the merits.

Section 22-3504(1) permits an illegal-sentence issue to be raised for the first time on appeal despite the defendant’s failure to raise it in the district court.

State v. McIntyre · filed 2018-07-06(1)

Because the Supreme Court has held that an illegal sentence issue may be considered for the first time on appeal, we find McIntyre may raise this issue on appeal despite his failure to do so below.

Section 22-3504(1) permits a defendant to challenge an illegal sentence for the first time on appeal.

State v. Owens · filed 2018-11-09(1)

"K.S.A. 22-3504(1) specifically authorizes a district court to 'correct an illegal sentence at any time,'" meaning a defendant may challenge a sentence as illegal for the first time on appeal.

Section 22-3504 treats a sentence that violates an applicable statutory limit on its term as an illegal sentence subject to correction.

State v. Dunn · filed 2019-07-05(3)

An illegal sentence within the meaning of K.S.A. 2018 Supp. 22-3504(3) is a sentence imposed by a court without jurisdiction; a sentence that does not conform to the applicable statutory provisions, either in character or term of authorized punishment; or a sentence ambiguous with respect to the time and manner in which it is to be served. ... By imposing a sentence less than 88 months, the district court violated K.S.A. 2018 Supp. 21-6818(a), rendering the sentence illegal.

Section 22-3504 allows an illegal sentence to be challenged at any time but does not itself give an appellate court jurisdiction over a State appeal alleging an illegal sentence.

State v. McCroy · filed 2020-01-10(1)

We hold that K.S.A. 22-3504 does not vest an appellate court with jurisdiction to consider a State's appeal solely on the claim that a sentence is illegal.

A presumptive guidelines sentence is reviewable under § 22-3504(1) as a claimed illegal sentence when the defendant contends that the sentencing judge misunderstood the scope of sentencing authority under another statute.

State v. Hildebrandt · filed 2000-10-27(1)

However, we agree with Hildebrandt’s assertion that his sentence is reviewable as a claimed illegal sentence under K.S.A. 22-3504(1) because of his contention that the trial judge misinterpreted the scope and extent of his authority under K.S.A. 22-3431.

Section 22-3504(1) treats a sentence as illegal if it lacks jurisdiction, does not conform to statutory sentencing provisions, or is ambiguous; a sentence calculated under the statutory formula for an attempted crime is not illegal on that ground.

McPherson v. State · filed 2007-08-10(1)

A sentence is illegal under K.S.A. 22-3504(1) if it imposed by a court without jurisdiction, does not conform to the statutory provision, or is ambiguous. ... Thus, the district court followed the statutory formula and did not impose an illegal sentence.

Section 22-3504 gives an appellate court jurisdiction to review a State challenge to an illegal sentence when the State asserts the sentence’s illegality throughout its appeal.

State v. Tims · filed 2014-01-03

In light of this record, we conclude that we have jurisdiction to consider the State’s appeal of Tims’ sentence as illegal under K.S.A. 22-3504 because, unlike in Berreth, the State has asserted the illegality of the sentence throughout its appeal.

Section 22-3504(1) permits a legal challenge to the classification of a prior adjudication for criminal history purposes to be raised for the first time on appeal.

State v. Mullens · filed 2015-10-30(1)

Initially, we note that although Mullens did not challenge the person classification of the 2003 Texas burglary in the district court, he may do so for the first time on appeal under State v. Dickey, 301 Kan. 1018, 1034, 350 P.3d 1054 (2015). In Dickey, our Supreme Court held that “a legal challenge to the classification of a prior adjudication ... be raised for the first time on appeal pursuant to K.S.A. 22-3504(1). [Citation omitted.]”

Section 22-3504(1) permits an appellate court to consider a claim that a sentence is illegal because prior convictions were misclassified, even when the defendant did not object at sentencing or file a motion to correct the sentence.

State v. Luarks · filed 2015-10-30(1)

Although Luarks has not filed a motion to correct illegal sentence under K.S.A. 22-3504(1), the substance of his arguments is that the district court imposed an illegal sentence—i.e., one that does not comply with the applicable statutory provision regarding the term of punishment authorized—because the court misclassified several prior convictions. See 301 Kan. at 1034. We have statutory authority to consider illegal sentence issues for the first time on appeal. See K.S.A. 22-3504(1); Dickey, 301 Kan. at 1034.

Section 22-3504 permits an illegal-sentence appeal when the defendant alleges that the sentencing court lacked jurisdiction to impose part of the sentence.

State v. Campbell · filed 2002-04-19

Although Campbell does not specifically claim his sentence was illegal, because Campbell alleges the district court lacked jurisdiction to impose a portion of his sentence, this court has jurisdiction to hear Campbell’s appeal as an appeal from an illegal sentence pursuant to K.S.A. 22-3504.

A district court considering a motion to correct an illegal sentence filed more than 10 days after sentencing must conduct a preliminary review comparable to review under K.S.A. 60-1507.

State v. Jones · filed 2011-08-12

In making his first argument that K.S.A. 60-1507 does not apply to his motion to correct an illegal sentence, which was filed pursuant to K.S.A. 22-3504, Jones fails to recognize that this court has directed district courts that are considering a motion to correct an illegal sentence filed more than 10 days after sentencing to conduct a prehminary review of the motion comparable to that conducted under the provisions of K.S.A. 60-1507.

Section 22-3504 permits correction of an illegal sentence at any time, but a sentence imposed in violation of Alleyne is not an illegal sentence under it.

State v. Trotter · filed 2021-04-30

But what constitutes an illegal sentence is not open ended, and this court has made clear that "a sentence imposed in violation of Alleyne does not fall within the definition of an 'illegal sentence' that may be addressed by K.S.A. 22-3504." Coleman, 312 Kan. at 120 (citing State v. Brown, 306 Kan. 330, Syl. ¶ 1, 393 P.3d 1049 [2017]; State v. Moncla, 301 Kan. 549, Syl. ¶ 4, 343 P.3d 1161 [2015]).

When a sentence is vacated in a proceeding to correct an illegal sentence and the defendant is resentenced, an appeal from the new sentence is a direct appeal that may benefit from changes in law occurring while it is pending.

State v. Smith · filed 2020-05-15

This distinction is critical because Smith's resentencing means that his current trip to the appellate courts is a direct appeal of that resentencing, despite his continuing to assert that the sentence imposed there was illegal.

Section 22-3504(a) permits an illegal sentence claim to be raised for the first time on appeal, but it does not itself give an appellate court jurisdiction.

State v. Love · filed 2020-07-31(a)

Kansas appellate courts have interpreted this provision to allow a defendant to challenge the legality of his or her sentence for the first time on appeal. See, e.g., State v. Sartin, 310 Kan. 367, 375, 446 P.3d 1068 (2019). The ability of a defendant to raise a claim for the first time on appeal, however, differs from a court's jurisdiction to hear an appeal. "Appellate jurisdiction defines our power to consider an appeal at all, regardless of the issues raised." State v. McCroy, 57 Kan. App. 2d 643, 458 P.3d 988, 992 (2020). K.S.A. 2019 Supp. 22-3504 itself does not vest an appellate court with jurisdiction.

Section 22-3504(a) allows a district court to address a motion to correct an illegal sentence even while an appeal is docketed.

State v. Peterson · filed 2021-03-05(a)

But under K.S.A. 22-3504, a court can correct an illegal sentence or a clerical mistake in judgement "at any time." K.S.A. 2020 Supp. 22-3504(a), (b). Thus, although Peterson's appeal of his probation revocations was docketed, the district court incorrectly found that it lacked jurisdiction to address Peterson's motion to correct illegal sentence.

Section 22-3504(c)(1) requires a colorable showing that a sentence is illegal; merely suggesting that prior convictions might have been uncounseled is insufficient.

State v. McCarty · filed 2021-03-26(c)(1)

Instead, McCarty only suggests a possible scenario under which his sentence may have been illegal. Given such briefing, we conclude McCarty has failed to make a colorable claim that his sentences were illegal under K.S.A. 2020 Supp. 22-3504(c)(1).

Section 22-3504 allows a challenge to an illegal sentence for the first time on direct appeal because an illegal sentence may be corrected at any time.

State v. Palmer · filed 2021-12-30

But because K.S.A. 2020 Supp. 22-3504 provides the legal authority to correct an illegal sentence at any time, we may consider Palmer's argument for the first time on appeal.

Section 22-3504 permits an illegal sentence challenge to be considered for the first time on direct appeal, even when the defendant did not object to the criminal history score below.

State v. Herrelson · filed 2022-01-07

While Herrelson did not object to his criminal history score below, he correctly notes we may consider an illegal sentence challenge for the first time on appeal. See State v. Hambright, 310 Kan. 408, 411, 447 P.3d 972 (2019) ("Under K.S.A. 22-3504, '[t]he court may correct an illegal sentence at any time,' and, therefore, this court may consider an illegal sentence challenge for the first time on direct appeal.").

A motion to correct an illegal sentence must be filed in the underlying criminal case in the court that imposed the sentence and may be filed while the defendant is serving that sentence.

Gaines v. Norwood · filed 2022-03-04

As provided in K.S.A. 2020 Supp. 22-3504, criminal defendants may file motions to correct illegal sentences at any time they are serving those sentences. The motion is to be filed in the underlying criminal case; it is considered a posttrial motion directed to the district court that imposed the sentence.

A postrelease supervision term that does not conform to the applicable sentencing statute is an illegal sentence requiring correction.

State v. Ware · filed 2024-09-27(c)(1)

We granted the motion for summary disposition and now agree that Ware's sentence is illegal and must be corrected on remand. See K.S.A. 22-3504(c)(1) (sentence is illegal when it does not conform to the applicable statutory provisions).

Section 22-3504 allows an illegal-sentence claim to be considered for the first time on appeal because an illegal sentence may be corrected at any time.

State v. Eubanks · filed 2022-08-26

But K.S.A. 2021 Supp. 22-3504 provides the legal authority to correct an illegal sentence at any time, so the panel appropriately considered Eubanks' argument for the first time on appeal.

Section 22-3504(a) permits a defendant to challenge the legality of a restitution order for the first time on appeal while serving the sentence.

State v. McBride · filed 2022-12-30(a)

While typically appellants cannot raise new issues on appeal, "certain issues, such as subject matter jurisdiction or an illegal sentence, can be raised at any time regardless of whether the issue was presented to the district court." State v. Johnson, 309 Kan. 992, 995, 441 P.3d 1036 (2019); see K.S.A. 2021 Supp. 22-3504(a) ("The court may correct an illegal sentence at any time while the defendant is serving such sentence."). Restitution is part of a defendant's sentence. State v. Hall, 298 Kan. 978, 983, 319 P.3d 506 (2014); see also State v. Eubanks, 316 Kan. 355, 360, 516 P.3d 116 (2022) (considering illegal sentence challenge based on restitution order for first time on appeal). As a result, McBride can challenge the legality of his restitution order on appeal for the first time.

An illegal sentence claim may be raised for the first time on appeal.

State v. Lawson · filed 2024-05-10

Although Lawson challenges his criminal history score for the first time on appeal, an illegal sentence claim can be newly raised on appeal.

Section 22-3504(a) permits a defendant to challenge a restitution order as an illegal sentence for the first time on appeal while serving the sentence.

State v. Baker · filed 2024-06-07(a)

In addition, Baker correctly points out we can consider his restitution challenge as an illegal sentence claim because restitution is part of a defendant's sentence. State v. Hall, 298 Kan. 978, 983, 319 P.3d 506 (2014); see Eubanks, 316 Kan. at 360 (considering illegal sentence challenge based on restitution order for first time on appeal); State v. Johnson, 309 Kan. 992, 995, 441 P.3d 1036 (2019); see also K.S.A. 22-3504(a) ("The court may correct an illegal sentence at any time while the defendant is serving such sentence."). Thus, Baker can challenge the legality of his restitution order for the first time on appeal.

Section 22-3504(a) allows an appellate court to correct an illegal sentence at any time while the defendant is serving it, even when the issue was not raised in district court.

State v. Phipps · filed 2023-10-20(a)

While Phipps did not raise this issue before the district court, he is serving an illegal sentence if his argument is correct. An appellate court may correct an illegal sentence at any time while the defendant is serving the sentence. K.S.A. 2022 Supp. 22- 3504(a); State v. Louis, 305 Kan. 453, 466, 384 P.3d 1 (2016).

Section 22-3504 permits an illegal-sentence claim to be considered for the first time on appeal because an illegal sentence may be corrected at any time.

State v. Casteel · filed 2025-06-13(a)

Accordingly, although Casteel did not raise this issue at the district court, we may consider it for the first time on appeal as an issue raising a claim of an illegal sentence— which may be corrected at any time—or, alternatively, under the exception for issues involving only a question of law arising on proved or admitted facts, which is finally determinative of the case.

Section 22-3504(a) allows an appellate court to consider an illegal-sentence challenge raised for the first time on appeal while the sentence is still being served.

State v. Lopez-Ramos · filed 2025-08-22(a)

Lopez-Ramos did not raise this issue before the district court, but an illegal sentence may be corrected at any time while the sentence is still being served. K.S.A. 22- 3504(a). So we may consider his argument for the first time on appeal.

Section 22-3504 permits a defendant to challenge an illegal sentence, including the criminal history score, for the first time on appeal.

State v. Hatley · filed 2026-01-30

For the first time on appeal, Hatley challenges her criminal history score. A defendant may raise the issue of an illegal sentence, including challenges to his or her criminal history score, for the first time on appeal. See K.S.A. 22-3504; State v. Steinert, 317 Kan. 342, 351-52, 529 P.3d 778 (2023). Therefore, we will address this argument.

Section 22-3504 permits a defendant serving a sentence to raise an illegal sentence claim for the first time on appeal.

State v. Jones · filed 2026-06-12

Jones did not raise this claim in district court. But because he is arguing his sentence is illegal, which he can do at any time while he is serving the sentence, this court may address the merits of his claim. See K.S.A. 22-3504 (court may review illegal sentence at any time while defendant is serving the sentence, and illegal sentence includes sentence that does not comport with applicable statute).

Section 22-3504 allows a court to review a claimed illegal sentence while the defendant is serving it, even if the claim was not raised in district court.

State v. Koch · filed 2026-02-27

Koch did not present this claim to the district court. But because he is claiming his sentence is illegal, which he can do any time he is serving the sentence, we will address the merits of his claim. See K.S.A. 22-3504 (court may review illegal sentence any time defendant is serving the sentence, and illegal sentence includes sentence that does not comport with applicable statute).

Section 22-3504(a) permits a defendant serving a sentence to challenge its legality at any time, including for the first time on appeal.

State v. Aguilera · filed 2026-04-24(a)

Although Aguilera did not challenge the length of his sentence before the district court, an illegal sentence may be raised at any time while the defendant is serving the sentence, including the first time on appeal. K.S.A. 22-3504(a); State v. Steinert, 317 Kan. 342, 351-52, 529 P.3d 778 (2023). Accordingly, we may consider Aguilera's challenge to the legality of his sentence.

A motion to correct an illegal sentence may raise claims omitted from a direct appeal without being barred by the rule requiring claims to be raised on direct appeal.

State v. Cox · filed 2026-02-27

A motion to correct an illegal sentence is an exception to the general rule that all claims must be raised on direct appeal or deemed waived.

Section 22-3504(a) permits review of an illegal sentence at any time while the defendant is serving it.

State v. Powell · filed 2026-03-06(a)

Because an illegal sentence may be reviewed at any time while a defendant is serving that sentence, we will review this claim.

Section 22-3504(a) allows a court to review an illegal-sentence argument first raised on appeal despite ordinary preservation rules.

State v. Brown · filed 2026-06-18(a)

And although the arguments in Brown's brief are raised for the first time on appeal, we may correct an illegal sentence at any time. See K.S.A. 22-3504(a); State v. Steinert, 317 Kan. 342, 351-52, 529 P.3d 778 (2023). Thus, we review Brown's newly asserted arguments despite our traditional preservation rules.

Section 22-3504 does not treat a claim that a sentence violates a constitutional provision as a claim of an illegal sentence.

State v. Moreno · filed 2020-05-08(a)

But a claim that a sentence violates a constitutional provision does not make the sentence illegal within the meaning of K.S.A. 2018 Supp. 22-3504, so Moreno had only 14 days to appeal his sentence.

A prison sentence is illegal under § 22-3504(c)(1) when the court disregards a presumption of probation without using the required departure procedure.

State v. Demoss · filed 2021-03-12(c)(1)

Rather, the district court incorrectly reasoned it could and should rely on the off-grid sentences imposed in the other cases to drive the punishment for the unlawful voluntary sexual relations convictions, resulting in presumptive incarceration. That mistaken reasoning produced an illegal sentence. See K.S.A. 2020 Supp. 22-3504(c)(1). We, therefore, vacate the sentences the district court imposed on Demoss for the convictions for unlawful voluntary sexual relations and remand for the imposition of statutorily proper sentences.

Section 22-3504 does not treat a sentence as illegal merely because it allegedly violates a constitutional provision.

State v. Heller · filed 2021-06-11

And a claim that a sentence violates a constitutional provision does not make the sentence illegal under K.S.A. 2020 Supp. 22-3504.

A claim that a sentence violates the constitution does not make it an illegal sentence correctable at any time under § 22-3504.

State v. Rogers · filed 2021-06-18

And a claim that a sentence violates a constitutional provision does not make the sentence illegal under K.S.A. 2020 Supp. 22-3504, allowing it to be corrected at any time.

A sentence that fails to comply with mandatory drug-treatment requirements is illegal and may be challenged for the first time on appeal.

State v. Brown · filed 2022-07-01(c)(1)

Though appellate courts, as courts of review, are generally loath to consider issues for the first time on appeal, we may do so here because our court has recognized on several occasions that a sentence that fails to comply with Senate Bill 123 requirements is illegal and may be challenged at any time. ... see also K.S.A. 2021 Supp. 22-3504(c)(1) (illegal sentence "does not conform to the applicable statutory provision, either in character or punishment").

Section 22-3504(c)(1) allows appellate review of a presumptive sentence when it violates another sentencing statute or is ambiguous about when and how it is to be served.

State v. McMillan · filed 2024-08-09(c)(1)

Thus, while many presumptive sentences must evade appellate review, appellate courts may review even a presumptive sentence if some aspect of it is illegal under another sentencing statute or is ambiguous as to time and manner of service.

Whether a sentence is illegal under § 22-3504 is a question of law subject to unlimited appellate review.

State v. Larkin · filed 2017-12-15

Whether a sentence is illegal within the meaning of K.S.A. 22-3504 is a question of law over which the appellate court has unlimited review.

Whether a sentence is illegal under § 22-3504 is a question of law subject to unlimited appellate review.

State v. Miller · filed 2016-06-24

Whether a sentence is illegal within the meaning of K.S.A. 22-3504 is a question of law over which the appellate court has unlimited review.

Whether a sentence is illegal under § 22-3504 is a question of law subject to unlimited appellate review.

State v. Hill · filed 2016-11-23

Whether a sentence is illegal under the meaning of K.S.A. 22-3504 is also a question of law over which the appellate court has unlimited review.

Whether a sentence is illegal within the meaning of § 22-3504 is a question of law subject to unlimited appellate review.

State v. Rothstein · filed 2016-12-02

Also, whether a sentence is illegal within the meaning of K.S.A. 22-3504 is a question of law over which the appellate court has unlimited review.

Whether a sentence is illegal under § 22-3504 is a question of law subject to unlimited appellate review.

State v. McClellan · filed 2017-03-03

Whether a sentence is illegal under K.S.A. 22-3504 is a question of law over which this court has unlimited review.

Whether a sentence is illegal under § 22-3504 is a question of law reviewed without deference.

State v. Powell · filed 2017-03-17

Whether a sentence is illegal within the meaning of K.S.A. 22-3504 is a question of law over which we exercise unlimited review.

Whether a sentence is illegal under Section 22-3504 is a question of law subject to unlimited appellate review.

State v. Clark · filed 2017-04-14

Whether a sentence is illegal within the meaning of K.S.A. 22-3504 is a question of law over which the appellate court has unlimited review.

Whether a sentence is illegal under § 22-3504 is a question of law subject to unlimited appellate review.

State v. Cooper · filed 2017-08-25

Whether a sentence is illegal within the meaning of K.S.A. 22-3504 is a question of law over which appellate courts exercise unlimited review.

A defendant may challenge an illegal sentence for the first time on appeal, and whether a sentence is illegal is reviewed as a question of law without deference.

State v. Patrick · filed 2018-09-14

For the first time on appeal, Patrick contends the district court imposed an illegal sentence when it classified his 1999 conviction for driving while a habitual offender as a nonperson felony for criminal history purposes. We may consider this issue because a defendant may challenge a sentence for the first time on appeal. State v. Fisher, 304 Kan. 242, 263-64, 373 P.3d 781 (2016). "Whether a sentence is illegal within the meaning of K.S.A. 22-3504 is a question of law over which the appellate court has unlimited review." 304 Kan. at 263.

Whether a sentence is illegal under § 22-3504 is a question of law subject to unlimited appellate review.

State v. McGinn · filed 2018-07-20

Whether a sentence is illegal under K.S.A. 22-3504 is a question of law over which the appellate court has unlimited review.

Whether a sentence is illegal under § 22-3504 is a question of law subject to unlimited appellate review.

State v. Anno · filed 2019-04-05

Whether a sentence is illegal under K.S.A. 22-3504 is a question of law over which we have unlimited review.

Whether a sentence is illegal under Section 22-3504 is a question of law subject to unlimited appellate review.

State v. Ross · filed 2019-11-01

Whether a sentence is illegal under K.S.A. 22-3504 is a question of law over which an appellate court exercises unlimited review.

Whether a sentence is illegal under § 22-3504 is a question of law subject to unlimited appellate review.

State v. Kanatzar · filed 2020-02-07

Whether a sentence is illegal within the meaning of K.S.A. 22-3504 is a question of law over which appellate courts have unlimited review.

Summary denial of a motion to correct an illegal sentence under § 22-3504 is reviewed de novo.

State v. Howard · filed 2008-12-19

Because this court has treated K.S.A. 60-1507 motions in the same manner as it has treated motions to correct an illegal sentence, we conclude that whether a district court erred in summarily denying the latter is also reviewed de novo.

Denial of a motion to correct an illegal sentence is reviewed de novo because the appellate court has the same access to the motion, records, and files as the district court.

State v. Phillips · filed 2013-10-25

In considering Phillips’ argument that the court erred in denying his motion to correct an illegal sentence, we apply a de novo standard of review. This is because the reviewing court has the same access to the motion, records, and files as the district court.

A court may summarily deny a motion to correct an illegal sentence if preliminary review finds no substantial question of law or fact.

State v. Davis · filed 2001-07-13(1)

Although Davis couched his arguments in terms of a motion to correct an illegal sentence, his arguments were actually pertaining to the ineffectiveness of his trial counsel. ... In both cases, the district court is to make a preliminary examination to determine whether substantial questions of law or fact are raised, and if the findings are in the negative, the court may summarily deny the motion.

Whether a sentence is illegal under § 22-3504 receives unlimited appellate review, and a summary denial of a motion to correct an illegal sentence receives de novo review.

State v. Claiborne · filed 2022-05-06

Whether a sentence is illegal within the meaning of K.S.A. 22-3504 is a question of law over which the appellate court has unlimited review. State v. Sartin, 310 Kan. 367, 369, 446 P.3d 1068 (2019). When a district court summarily denies a motion to correct illegal sentence, the appellate court applies a de novo standard of review because the appellate court has the same access to the motion, records, and files as the district court. State v. Alford, 308 Kan. 1336, 1338, 429 P.3d 197 (2018).

An appellate court exercises unlimited review when determining whether a sentence is illegal under § 22-3504.

State v. Daniels · filed 2023-01-06

Appellate courts exercise unlimited review when determining whether a sentence is illegal under K.S.A. 22-3504.