17 Kansas opinions name it 2 courts 2017–2025 11 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 |
|---|---|---|
State v. Edgargreen2 sentences2024Generally, a defendant "must establish that no reasonable person would have agreed with the district court's assessment of the three Edgar factors and its ultimate conclusions." State v. Reu-El, 306 Kan. 460 , 472, 394 P.3d 884 (2017) (citing State v. Edgar, 281 Kan. 30, 37-38 , 127 P.3d 986 [2006]). 2024Generally, a defendant "must establish that no reasonable person would have agreed with the district court's assessment of the three Edgar factors and its ultimate conclusions." State v. Reu-El, 306 Kan. 460 , 472, 394 P.3d 884 (2017) (citing State v. Edgar, 281 Kan. 30, 37-38 , 127 P.3d 986 [2006]). | 3 | 13 |
State v. Glovergreen2 sentences2018"All of the Edgar factors need not apply in a defendant's favor in every case, and other factors may be duly considered in the district judge's discretionary decision on the existence or nonexistence of good cause." State v. Aguilar , 290 Kan. 506 , 513, 231 P.3d 563 (2010) ; see State v. Glover , 50 Kan. 2017"All of the Edgar factors need not apply in a defendant's favor in every case, and other factors may be duly considered in the district judge's discretionary decision on the existence or nonexistence of good cause." State v. Aguilar, 290 Kan. 506, 513 , 231 P.3d 563 (2010); see State v. Glover, 50 Kan. | 2 | 2 |
State v. Aguilargreen2 sentences2024Later, in State v. Aguilar, 290 Kan. 506 , 8 512-13, 231 P.3d 563 (2010), our Supreme Court clarified that the three Edgar factors were nonexclusive factors. 2024Later, in State v. Aguilar, 290 Kan. 506 , 8 512-13, 231 P.3d 563 (2010), our Supreme Court clarified that the three Edgar factors were nonexclusive factors. | 1 | 4 |
State v. Mosesgreen2 sentences2020Johnson, 307 Kan. at 443 ; see State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 96 (2006); see also State v. Moses, 280 Kan. 939, 950-54 , 127 P.3d 330 (2006) (noting other factors may support denial of postsentence motion to withdraw plea, including reasonable promptness of motion; defendant's failure to raise issue in prior direct appeal or K.S.A. 60-1507 proceeding; prejudice to State; defendant's prior involvement in criminal justice system; and defendant's receipt of favorable plea bargain). 2020Johnson, 307 Kan. at 443 ; see State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 96 (2006); see also State v. Moses, 280 Kan. 939, 950-54 , 127 P.3d 330 (2006) (noting other factors may support denial of postsentence motion to withdraw plea, including reasonable promptness of motion; defendant's failure to raise issue in prior direct appeal or K.S.A. 60-1507 proceeding; prejudice to State; defendant's prior involvement in criminal justice system; and defendant's receipt of favorable plea bargain). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Kansas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Morris
green
2 sentences2022When determining whether a movant has established manifest injustice, courts in this state generally consider the three Edgar factors: "'(1) whether the defendant was represented by competent counsel; (2) whether the defendant was misled, coerced, mistreated, or unfairly taken advantage of; and (3) whether the plea was fairly and understandingly made.'" State v. Morris, 298 Kan. 1091, 1100 , 319 P.3d 539 (2014) (citing State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 [2006]). 2022When determining whether a movant has established manifest injustice, courts in this state generally consider the three Edgar factors: "'(1) whether the defendant was represented by competent counsel; (2) whether the defendant was misled, coerced, mistreated, or unfairly taken advantage of; and (3) whether the plea was fairly and understandingly made.'" State v. Morris, 298 Kan. 1091, 1100 , 319 P.3d 539 (2014) (citing State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 [2006]). | 3 | 2017–2022 |
State v. Woodring
green
2 sentences2020Whether good cause exists is analyzed using the three Edgar factors: "'whether "(1) the defendant was represented by competent counsel, (2) the defendant was misled, coerced, mistreated, or unfairly taken advantage of, and (3) the plea was fairly and understandingly made."' State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006)." Woodring, 309 Kan. at 381 . 2020Woodring, 309 Kan. at 381 (quoting Edgar, 281 Kan. at 36 ). | 2 | 2020–2020 |
State v. Frazier
green
1 sentence2024State v. Frazier, 311 Kan. 378 , 381, 461 P.3d 43 (2020). | 1 | 2024–2024 |
State v. DeAnda
green
1 sentence2022But district courts typically consider the three Edgar factors when analyzing whether good cause has been shown: "(1) whether 'the defendant was represented by competent counsel'; (2) whether 'the defendant was misled, coerced, mistreated, or unfairly taken advantage of'; and (3) whether 'the plea was fairly and understandingly made.'" DeAnda, 307 Kan. at 503 ; Edgar, 281 Kan. at 36 . | 1 | 2022–2022 |
State v. Adams
green
1 sentence2022See K.S.A. 2020 Supp. 22- 3210(d)(2); State v. Adams, 311 Kan. 569 , 575, 465 P.3d 176 (2020). | 1 | 2022–2022 |
State v. Rodriguez
green
2 sentences2017In making that argument, Amman Reu-El points to this court's statement in State v. Rodriguez, 254 Kan. 768, 775 , 869 P.2d 631 (1994) (Rodriguez I), that "[i]f indeed the trial judge misinformed [a defendant] of the consequences of his plea, [the defendant] can have the plea set aside as not voluntarily and intelligently made." Amman Reu-El also cites an unpublished opinion of the Kansas Court of Appeals, which held that another consideration is whether defense counsel inaccurately advised that a pretrial ruling could be appealed even after a 17 no contest plea. 2017In making that argument, Amman Reu-El points to this court's statement in State v. Rodriguez, 254 Kan. 768, 775 , 869 P.2d 631 (1994) (Rodriguez I), that "[i]f indeed the trial judge misinformed [a defendant] of the consequences of his plea, [the defendant] can have the plea set aside as not voluntarily and intelligently made." Amman Reu-El also cites an unpublished opinion of the Kansas Court of Appeals, which held that another consideration is whether defense counsel inaccurately advised that a pretrial ruling could be appealed even after a 17 no contest plea. | 1 | 2017–2017 |
State v. Bricker
green
2 sentences2017K.S.A. 2016 Supp. 22-3210(d)(2) states: "To correct manifest injustice the court after sentence may set aside the judgment of conviction and permit the defendant to withdraw the plea." Courts in this state generally consider the three Edgar factors when judging whether a movant has established manifest injustice: "'(1) whether the defendant was represented by competent counsel; (2) whether the defendant was misled, coerced, mistreated, or unfairly taken advantage of; and (3) whether the plea was fairly and understandingly made.'" State v. Morris, 298 Kan. 1091, 1100 , 319 P.3d 539 (2014) (quot 2017K.S.A. 2016 Supp. 22-3210(d)(2) states: "To correct manifest injustice the court after sentence may set aside the judgment of conviction and permit the defendant to withdraw the plea." Courts in this state generally consider the three Edgar factors when judging whether a movant has established manifest injustice: "'(1) whether the defendant was represented by competent counsel; (2) whether the defendant was misled, coerced, mistreated, or unfairly taken advantage of; and (3) whether the plea was fairly and understandingly made.'" State v. Morris, 298 Kan. 1091, 1100 , 319 P.3d 539 (2014) (quot | 1 | 2017–2017 |
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.