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32 Kansas opinions name it 2 courts 1980–2026 13 in the last five years
The cases below were cited by Kansas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
North Carolina v. Alfordgreen2 sentences2015Mashaney agreed to enter an Alford plea, see 400 U.S. at 37 , on two counts of attempted aggravated battery and one count of aggravated endangering a child. 2009As a result of L.H.D.’s death, Father entered an Alford plea to felony abuse of a child, see North Carolina v. Alford, 400 U.S. 25, 38 , 27 L. | 15 | 20 |
State v. Casegreen2 sentences2026Ed. 2d 162 (1970); State v. Case, 289 Kan. 457, 460 , 213 P.3d 429 (2009) ("An Alford plea is a 'plea of guilty to the charge without admitting to the commission of the offense.'"). 3 The plea agreement stated that Zarinegar would "pay full restitution of up to $235,500 to Phyllis Visser." In exchange for the plea, the State agreed to dismiss the remaining charges and recommend concurrent terms of probation that could be served in Arizona, where Zarinegar was facing federal securities charges. 2026Ed. 2d 162 (1970); State v. Case, 289 Kan. 457, 460 , 213 P.3d 429 (2009) ("An Alford plea is a 'plea of guilty to the charge without admitting to the commission of the offense.'"). 3 The plea agreement stated that Zarinegar would "pay full restitution of up to $235,500 to Phyllis Visser." In exchange for the plea, the State agreed to dismiss the remaining charges and recommend concurrent terms of probation that could be served in Arizona, where Zarinegar was facing federal securities charges. | 10 | 11 |
State v. Taylorgreen2 sentences2025See State v. Taylor, 266 Kan. 967, 969 , 975 P.2d 10 1196 (1999) (discussing Brady and Alford but indicating Alford is more applicable to the situation when a person enters a guilty plea without admitting to committing the offense). 2009Such an interpretation, of course, is directly contrary to the essence of an Alford plea: “plead[ing] guilty without admitting the acts of the crime.” (Emphasis added.) Taylor, 266 Kan. at 979 ; see Johnson, 255 Kan. at 157 (Alford plea “is a plea of guilty to the charge without admitting to the commission of the offense”). | 2 | 2 |
State v. Edgargreen2 sentences2012State v. Edgar, 281 Kan. 30, 42-43 , 127 P.3d 986 (2006) (Alford plea); State v. Shaw, 259 Kan. 3, 7 , 910 P.2d 809 (1996) (no contest plea). 2012State v. Edgar, 281 Kan. 30, 42-43 , 127 P.3d 986 (2006) (Alford plea); State v. Shaw, 259 Kan. 3, 7 , 910 P.2d 809 (1996) (no contest plea). | 1 | 2 |
State v. Johnsongreen2 sentences2009An Alford plea is a “plea of guilty to the charge without admitting to the commission of the offense.” State v. Johnson, 255 Kan. 156, 157 , 872 P.2d 247 (1994). 2009An Alford plea is a “plea of guilty to the charge without admitting to the commission of the offense.” State v. Johnson, 255 Kan. 156, 157 , 872 P.2d 247 (1994). | 1 | 2 |
State v. Walkergreen2 sentences2024See State v. Walker, 275 Kan. 46, 51 , 60 P.3d 937 (2003) ("A plea of guilty to a statutorily defined sexually violent crime provides the basis for an extended postrelease supervision period."); State v. Case, 289 Kan. 457, 467-68 , 213 P.3d 429 (2009) (stipulation to a factual basis within an Alford plea did not constitute an admission under Apprendi); State v. Allen, 283 Kan. 372, 377 , 153 P.3d 488 (2007) (a no contest plea in a prior case did not function as an admission and could not be used to increase the defendant's sentence); State v. Entsminger, No. 124,800, 2023 WL 2467058 , at *6-8 2024See State v. Walker, 275 Kan. 46, 51 , 60 P.3d 937 (2003) ("A plea of guilty to a statutorily defined sexually violent crime provides the basis for an extended postrelease supervision period."); State v. Case, 289 Kan. 457, 467-68 , 213 P.3d 429 (2009) (stipulation to a factual basis within an Alford plea did not constitute an admission under Apprendi); State v. Allen, 283 Kan. 372, 377 , 153 P.3d 488 (2007) (a no contest plea in a prior case did not function as an admission and could not be used to increase the defendant's sentence); State v. Entsminger, No. 124,800, 2023 WL 2467058 , at *6-8 | 1 | 1 |
Farris v. McKunegreen2 sentences2024In turn, the district court accepts the proffer for the limited purpose of establishing a factual basis to accept the plea and to find the defendant guilty. 289 Kan. at 464-65 ; see K.S.A. 22-3210(a)(4) (district court must be "satisfied that there is a factual basis" for plea of guilty or no contest). 8 But the proffer does not then become a set of proved or admitted facts that can otherwise be attributed to or used against the defendant. 289 Kan. at 466 ("In an Alford plea, failure or even refusal to object to the presented facts or to put on evidence does not equate to an admission of facts 2024In turn, the district court accepts the proffer for the limited purpose of establishing a factual basis to accept the plea and to find the defendant guilty. 289 Kan. at 464-65 ; see K.S.A. 22-3210(a)(4) (district court must be "satisfied that there is a factual basis" for plea of guilty or no contest). 8 But the proffer does not then become a set of proved or admitted facts that can otherwise be attributed to or used against the defendant. 289 Kan. at 466 ("In an Alford plea, failure or even refusal to object to the presented facts or to put on evidence does not equate to an admission of facts | 1 | 1 |
State v. Alfordgreen2 sentences2024The Alford court found neither argument persuasive. 257 Kan. at 838, 840 . 2 The Kansas Supreme Court also rejected Alford's claim that the district court erred when it admitted a written statement by Jackson describing a previous beating by Alford. 2024Though Alford did not object to the admission of this statement at trial, and so the issue was not preserved for appeal, the court nevertheless reached the merits of Alford's claim and found that the statement was admissible. 257 Kan. at 840 . | 1 | 1 |
Cranford v. Stategreen1 sentence2024Moreover, in Farris, the court recognized that a no-contest plea and the resulting finding of guilty constituted no more than an admission of the "well-pleaded facts" of the charging instrument "for purposes of the case." 259 Kan. at 194 ; see Cranford v. State, 39 Kan. | 1 | 1 |
United States v. Ronald L. Tunninggreen1 sentence2009This can be accomplished in two ways: “without admitting the acts of the crime or even protesting innocence, if the defendant intelligently concludes defendant’s interest so requires.” State v. Taylor, 266 Kan. 967, 979 , 975 P.2d 1196 (1999); see United States v. Tunning, 69 F.3d 107, 111 (6th Cir. 1995) (The two possible Alford-type guilty pleas are when the defendant affirmatively protests his or her innocence or refuses *461 to admit to acts constituting a crime.) (cited in State v. Edgar, 281 Kan. 30, 43 , 127 P.3d 986 [2006]). | 1 | 1 |
Witt v. Stategreen1 sentence2001See Witt v. State, 197 Kan. 363 , Syl. ¶ 2, 416 *801 P.2d 717 (1966); Cooper v. State, 196 Kan. 421 , Syl. ¶ 4, 411 P.2d 652 (1966); Moore v. Hand, 187 Kan. 260, 263 , 356 P.2d 809 (1960).” An Alford plea allows a defendant to knowingly and intelligently plead guilty, based on the strength of the prosecution’s case, without the express admission of guilt, in order to take advantage of plea negotiations. | 1 | 1 |
Doyle v. Kellygreen1 sentence2001See Witt v. State, 197 Kan. 363 , Syl. ¶ 2, 416 *801 P.2d 717 (1966); Cooper v. State, 196 Kan. 421 , Syl. ¶ 4, 411 P.2d 652 (1966); Moore v. Hand, 187 Kan. 260, 263 , 356 P.2d 809 (1960).” An Alford plea allows a defendant to knowingly and intelligently plead guilty, based on the strength of the prosecution’s case, without the express admission of guilt, in order to take advantage of plea negotiations. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Kansas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Bellamy v. State
green
2 sentences2024Bellamy v. State, 285 Kan. 346, 354 , 172 P.3d 10 (2007). 2024Bellamy v. State, 285 Kan. 346, 354 , 172 P.3d 10 (2007). | 1 | 2024–2024 |
State v. Allen
green
2 sentences2024See State v. Walker, 275 Kan. 46, 51 , 60 P.3d 937 (2003) ("A plea of guilty to a statutorily defined sexually violent crime provides the basis for an extended postrelease supervision period."); State v. Case, 289 Kan. 457, 467-68 , 213 P.3d 429 (2009) (stipulation to a factual basis within an Alford plea did not constitute an admission under Apprendi); State v. Allen, 283 Kan. 372, 377 , 153 P.3d 488 (2007) (a no contest plea in a prior case did not function as an admission and could not be used to increase the defendant's sentence); State v. Entsminger, No. 124,800, 2023 WL 2467058 , at *6-8 2024See State v. Walker, 275 Kan. 46, 51 , 60 P.3d 937 (2003) ("A plea of guilty to a statutorily defined sexually violent crime provides the basis for an extended postrelease supervision period."); State v. Case, 289 Kan. 457, 467-68 , 213 P.3d 429 (2009) (stipulation to a factual basis within an Alford plea did not constitute an admission under Apprendi); State v. Allen, 283 Kan. 372, 377 , 153 P.3d 488 (2007) (a no contest plea in a prior case did not function as an admission and could not be used to increase the defendant's sentence); State v. Entsminger, No. 124,800, 2023 WL 2467058 , at *6-8 | 1 | 2024–2024 |
Alford v. State
green
1 sentence2024This court affirmed the district court's ruling on appeal. 2010 WL 174001, at *4 . 5 Seven years later, in 2014, Alford filed with the district court a motion to reinstate the appeal of his first K.S.A. 60-1507 motion. | 1 | 2024–2024 |
Robinson v. State
green
1 sentence2020Spooner's reliance on Robinson v. State, 56 Kan. | 1 | 2020–2020 |
Mashaney v. Board of Indigents' Defense Services
green
1 sentence2015Mashaney v. Board of Indigents’ Defense Services, 49 Kan. | 1 | 2015–2015 |
Apprendi v. New Jersey
green
1 sentence2012Unrein’s argument on appeal is predicated on Apprendi’s holding: “Other than the facts 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 . | 1 | 2012–2012 |
State v. Shaw
green
2 sentences2012State v. Edgar, 281 Kan. 30, 42-43 , 127 P.3d 986 (2006) (Alford plea); State v. Shaw, 259 Kan. 3, 7 , 910 P.2d 809 (1996) (no contest plea). 2012State v. Edgar, 281 Kan. 30, 42-43 , 127 P.3d 986 (2006) (Alford plea); State v. Shaw, 259 Kan. 3, 7 , 910 P.2d 809 (1996) (no contest plea). | 1 | 2012–2012 |
State v. McCray
green
2 sentences2009The Court of Appeals’ decision in State v. McCray, 32 Kan. 2009It seems particularly counterproductive to require discussion with the defendant regarding the factual basis to support an Alford plea; the very nature of such a plea makes it unlikely that the defendant would agree with or accept the factual basis since it would presumably undermine his purported innocence.” (Emphasis added.) 32 Kan. | 1 | 2009–2009 |
Parson v. Carroll
green
2 sentences2009Similarly, in Parson v. Carroll, 272 Va. 560, 566 , 636 S.E.2d 452 (2006), defense counsel told the court that based on his client’s Alford pleas — where he did not admit the crime — that nevertheless, “[w]e would stipulate that the evidence as presented and if believable would have been sufficient.” (Emphasis added.) Despite our construction and treatment of the plea agreement, and the panel’s own acknowledgment that Case “entered an Alford plea to the charges against him” {Case, 2008 WL 2425674 , at *3), the panel seems to suggest that statements and occurrences at the plea hearing essential 2009Similarly, in Parson v. Carroll, 272 Va. 560, 566 , 636 S.E.2d 452 (2006), defense counsel told the court that based on his client’s Alford pleas — where he did not admit the crime — that nevertheless, “[w]e would stipulate that the evidence as presented and if believable would have been sufficient.” (Emphasis added.) Despite our construction and treatment of the plea agreement, and the panel’s own acknowledgment that Case “entered an Alford plea to the charges against him” {Case, 2008 WL 2425674 , at *3), the panel seems to suggest that statements and occurrences at the plea hearing essential | 1 | 2009–2009 |
Cooper v. State
neutral
2 sentences2001See Witt v. State, 197 Kan. 363 , Syl. ¶ 2, 416 *801 P.2d 717 (1966); Cooper v. State, 196 Kan. 421 , Syl. ¶ 4, 411 P.2d 652 (1966); Moore v. Hand, 187 Kan. 260, 263 , 356 P.2d 809 (1960).” An Alford plea allows a defendant to knowingly and intelligently plead guilty, based on the strength of the prosecution’s case, without the express admission of guilt, in order to take advantage of plea negotiations. 2001See Witt v. State, 197 Kan. 363 , Syl. ¶ 2, 416 *801 P.2d 717 (1966); Cooper v. State, 196 Kan. 421 , Syl. ¶ 4, 411 P.2d 652 (1966); Moore v. Hand, 187 Kan. 260, 263 , 356 P.2d 809 (1960).” An Alford plea allows a defendant to knowingly and intelligently plead guilty, based on the strength of the prosecution’s case, without the express admission of guilt, in order to take advantage of plea negotiations. | 1 | 2001–2001 |
Moore v. Hand
neutral
2 sentences2001See Witt v. State, 197 Kan. 363 , Syl. ¶ 2, 416 *801 P.2d 717 (1966); Cooper v. State, 196 Kan. 421 , Syl. ¶ 4, 411 P.2d 652 (1966); Moore v. Hand, 187 Kan. 260, 263 , 356 P.2d 809 (1960).” An Alford plea allows a defendant to knowingly and intelligently plead guilty, based on the strength of the prosecution’s case, without the express admission of guilt, in order to take advantage of plea negotiations. 2001See Witt v. State, 197 Kan. 363 , Syl. ¶ 2, 416 *801 P.2d 717 (1966); Cooper v. State, 196 Kan. 421 , Syl. ¶ 4, 411 P.2d 652 (1966); Moore v. Hand, 187 Kan. 260, 263 , 356 P.2d 809 (1960).” An Alford plea allows a defendant to knowingly and intelligently plead guilty, based on the strength of the prosecution’s case, without the express admission of guilt, in order to take advantage of plea negotiations. | 1 | 2001–2001 |
State v. Reed
green
1 sentence1999We said in State v. Johnson, 255 Kan. 156, 157 , 872 P.2d 247 (1994), that an Alford plea was a “plea of guilty to the charge without admitting to the commission of the offense.” See Reed, 248 Kan. at 510-11 , for an Alford plea discussion. | 1 | 1999–1999 |
Brady v. United States
green
1 sentence1999The Supreme Court, in Brady, held that a guilty plea otherwise voluntarily and intelligently made with competent counsel is not. invalid because the plea is motivated by a desire to avoid the death penalty or to obtain a lesser sentence. 397 U.S. 742 . | 1 | 1999–1999 |
United States v. I. James Bednarski, Jr.
green
1 sentence1980We could not support a principle under which, if the court refused to accept the plea, the defendant after trial and a conviction and a sentence not to his liking could return and freely litigate the correctness of the court’s finding that the requirements of Rule 11 had not been fully met.” 445 F.2d at 366 . | 1 | 1980–1980 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.