Edgar factors in Kansas

104 Kansas opinions name it 2 courts 2006–2026 55 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.

Followed or applied (23)

Case	Followed	Cited
State v. Edgargreen kan · 2006 · cited in 72 Kansas opinions naming this issue, 2010–2026 2 sentences 2025These three factors are known as the Edgar factors, as established in State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006); see also State v. Johnson, 307 Kan. 436 , 443, 410 P.3d 913 (2018) (applying Edgar factors to review a ruling on a postsentence motion to withdraw a plea). 2025These three factors are known as the Edgar factors, as established in State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006); see also State v. Johnson, 307 Kan. 436 , 443, 410 P.3d 913 (2018) (applying Edgar factors to review a ruling on a postsentence motion to withdraw a plea).	17	72
State v. Aguilargreen kan · 2010 · cited in 42 Kansas opinions naming this issue, 2010–2025 2 sentences 2025All three Edgar factors "need not apply in a defendant's favor in every case." State v. Aguilar, 290 Kan. 506, 513 , 231 P.3d 563 (2010). 2025All three Edgar factors "need not apply in a defendant's favor in every case." State v. Aguilar, 290 Kan. 506, 513 , 231 P.3d 563 (2010).	6	42
State v. Williamsgreen kan · 2010 · cited in 8 Kansas opinions naming this issue, 2020–2022 2 sentences 2022State v. Garcia, 295 Kan. 53, 62-63 , 283 P.3d 165 (2012) (noting that these considerations— commonly known as the Edgar factors—establish a sound benchmark); State v. Williams, 290 Kan. 1050, 1053 , 236 P.3d 512 (2010); State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006). 2022State v. Garcia, 295 Kan. 53, 62-63 , 283 P.3d 165 (2012) (noting that these considerations— commonly known as the Edgar factors—establish a sound benchmark); State v. Williams, 290 Kan. 1050, 1053 , 236 P.3d 512 (2010); State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006).	6	8
State v. Schowgreen kan · 2008 · cited in 7 Kansas opinions naming this issue, 2010–2026 2 sentences 2026See State v. Schow, 287 Kan. 529, 544-46 , 197 P.3d 825 (2008) (explaining that when a presentence motion to withdraw a plea is based on a mistake about criminal history, courts may consider the circumstances surrounding the misinformation to the extent they bear on the Edgar factors). 2026See State v. Schow, 287 Kan. 529, 544-46 , 197 P.3d 825 (2008) (explaining that when a presentence motion to withdraw a plea is based on a mistake about criminal history, courts may consider the circumstances surrounding the misinformation to the extent they bear on the Edgar factors).	5	7
State v. Garciagreen kan · 2012 · cited in 6 Kansas opinions naming this issue, 2020–2022 2 sentences 2022State v. Garcia, 295 Kan. 53, 62-63 , 283 P.3d 165 (2012) (noting that these considerations— commonly known as the Edgar factors—establish a sound benchmark); State v. Williams, 290 Kan. 1050, 1053 , 236 P.3d 512 (2010); State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006). 2022State v. Garcia, 295 Kan. 53, 62-63 , 283 P.3d 165 (2012) (noting that these considerations— commonly known as the Edgar factors—establish a sound benchmark); State v. Williams, 290 Kan. 1050, 1053 , 236 P.3d 512 (2010); State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006).	4	6
State v. DeAndagreen kan · 2018 · cited in 6 Kansas opinions naming this issue, 2020–2022 2 sentences 2022While defense counsel's competence is one consideration under the Edgar factors, it should not be "'mechanically applied to demand that a defendant demonstrate 5 ineffective assistance arising to the level of a violation of the Sixth Amendment' [to the United States Constitution] to demonstrate good cause . . . . 'Merely lackluster advocacy . . . may be plenty to support the first Edgar factor.' [Citations omitted.]" State v. DeAnda, 307 Kan. 500, 504 , 411 P.3d 330 (2018). 2022But 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 .	2	6
State v. Johnsongreen kan · 2018 · cited in 3 Kansas opinions naming this issue, 2020–2025 2 sentences 2025These three factors are known as the Edgar factors, as established in State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006); see also State v. Johnson, 307 Kan. 436 , 443, 410 P.3d 913 (2018) (applying Edgar factors to review a ruling on a postsentence motion to withdraw a plea). 2025These three factors are known as the Edgar factors, as established in State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006); see also State v. Johnson, 307 Kan. 436 , 443, 410 P.3d 913 (2018) (applying Edgar factors to review a ruling on a postsentence motion to withdraw a plea).	2	3
State v. Freemangreen kan · 2011 · cited in 3 Kansas opinions naming this issue, 2011–2021 2 sentences 2021See State v. Freeman, 292 Kan. 24, 30 , 253 P.3d 1 (2011). 2021See State v. Freeman, 292 Kan. 24, 30 , 253 P.3d 1 (2011).	2	3
State v. Glovergreen kanctapp · 2014 · cited in 2 Kansas opinions naming this issue, 2017–2018 2 sentences 2018"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. 2018"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. Andersongreen kan · 2011 · cited in 2 Kansas opinions naming this issue, 2011–2016 2 sentences 2016Aguilar, 290 Kan. at 512-13 ; see also State v. Anderson, 291 Kan. 849, 856 , 249 P.3d 425 (2011) ("The district court also may consider other factors when determining whether good cause is shown."). 2016Aguilar, 290 Kan. at 512-13 ; see also State v. Anderson, 291 Kan. 849, 856 , 249 P.3d 425 (2011) ("The district court also may consider other factors when determining whether good cause is shown.").	2	2
State v. Greengreen kan · 2007 · cited in 2 Kansas opinions naming this issue, 2011–2014 2 sentences 2014Edgar, 281 Kan. at 36 ; see State v. Green, 283 Kan. 531, 545-46 , 153 P.3d 1216 (2007) (applying the Edgar factors to a postsentence plea withdrawal case); see also State v. Aguilar, 290 Kan. 506, 511 , 231 P.3d 563 (2010) (collecting cases discussing the Edgar factors).” Bricker, 292 Kan. at 244-45 . 2014Edgar, 281 Kan. at 36 ; see State v. Green, 283 Kan. 531, 545-46 , 153 P.3d 1216 (2007) (applying the Edgar factors to a postsentence plea withdrawal case); see also State v. Aguilar, 290 Kan. 506, 511 , 231 P.3d 563 (2010) (collecting cases discussing the Edgar factors).” Bricker, 292 Kan. at 244-45 .	2	2
State v. Fraziergreen kan · 2020 · cited in 9 Kansas opinions naming this issue, 2021–2026 2 sentences 2026State v. Frazier, 311 Kan. 378 , 381, 461 P.3d 43 (2020); 5 Edgar, 281 Kan. at 36 . 2021See K.S.A. 2020 Supp. 22-3210(d)(1); State v. Frazier, 311 Kan. 378 , 381, 461 P.3d 43 (2020) (setting forth list of three nonexclusive Edgar factors to consider on presentence plea withdrawal motion).	1	9
State v. Fritzgreen kan · 2014 · cited in 9 Kansas opinions naming this issue, 2015–2024 2 sentences 2024These "Edgar factors" should not "be applied mechanically and to the exclusion of other factors." State v. Fritz, 299 Kan. 153, 154 , 321 P.3d 763 (2014); see State v. Schow, 287 Kan. 529, 542-43 , 197 P.3d 825 (2008) (referring to these three factors as "Edgar factors"). 2024These "Edgar factors" should not "be applied mechanically and to the exclusion of other factors." State v. Fritz, 299 Kan. 153, 154 , 321 P.3d 763 (2014); see State v. Schow, 287 Kan. 529, 542-43 , 197 P.3d 825 (2008) (referring to these three factors as "Edgar factors").	1	9
State v. Brickergreen kan · 2011 · cited in 5 Kansas opinions naming this issue, 2014–2026 2 sentences 2026The Edgar factors are not exclusive—rather, they provide "'viable benchmarks for judicial discretion.'" State v. Morris, 298 Kan. 1091, 1101 , 319 P.3d 539 (2014) (quoting State v. Bricker, 292 Kan. 239, 245 , 252 P.3d 118 [2011]). 2026The Edgar factors are not exclusive—rather, they provide "'viable benchmarks for judicial discretion.'" State v. Morris, 298 Kan. 1091, 1101 , 319 P.3d 539 (2014) (quoting State v. Bricker, 292 Kan. 239, 245 , 252 P.3d 118 [2011]).	1	5
State v. Woodringgreen kan · 2019 · cited in 4 Kansas opinions naming this issue, 2020–2023 2 sentences 2023State v. Woodring, 309 Kan. 379, 384 , 435 P.3d 54 (2019). 2020Whether 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 .	1	4
State v. Macias-Medinagreen kan · 2012 · cited in 2 Kansas opinions naming this issue, 2022–2025 2 sentences 2022Our Supreme Court has instructed "exclusive reliance on or mechanical application of the Edgar factors could distort the concept of good cause." State v. Macias-Medina, 293 Kan. 833, 837 , 268 P.3d 1201 (2012). 2022Our Supreme Court has instructed "exclusive reliance on or mechanical application of the Edgar factors could distort the concept of good cause." State v. Macias-Medina, 293 Kan. 833, 837 , 268 P.3d 1201 (2012).	1	2
State v. Adamsgreen kan · 2020 · cited in 2 Kansas opinions naming this issue, 2022–2022 2 sentences 2022See K.S.A. 2020 Supp. 22- 3210(d)(2); State v. Adams, 311 Kan. 569 , 575, 465 P.3d 176 (2020). 2022See State v. Adams, 311 Kan. 569 , 575, 465 P.3d 176 (2020); State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006).	1	2
State v. Shieldsgreen kan · 2022 · cited in 1 Kansas opinions naming this issue, 2024–2024 2 sentences 2024These three factors are known as the Edgar factors, but they are not the only consideration; "[a] district court may consider other relevant factors, and the defendant need not show that all the factors apply in his favor." Shields, 315 Kan. at 139-40; see State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006). 5 I. 2024These three factors are known as the Edgar factors, but they are not the only consideration; "[a] district court may consider other relevant factors, and the defendant need not show that all the factors apply in his favor." Shields, 315 Kan. at 139-40; see State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006). 5 I.	1	1
State v. Meggersongreen kan · 2020 · cited in 1 Kansas opinions naming this issue, 2024–2024 2 sentences 2024See State v. Meggerson, 312 Kan. 238 , 246, 474 P.3d 761 (2020). 2024See State v. Meggerson, 312 Kan. 238 , 246, 474 P.3d 761 (2020).	1	1
State v. Arnettgreen kan · 2018 · cited in 1 Kansas opinions naming this issue, 2022–2022	1	1
State v. WICKENgreen kanctapp · 2010 · cited in 1 Kansas opinions naming this issue, 2020–2020	1	1
State v. Mosesgreen kan · 2006 · cited in 1 Kansas opinions naming this issue, 2020–2020	1	1
Wirt v. Esreygreen kan · 1983 · cited in 1 Kansas opinions naming this issue, 2015–2015	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Kansas. Read the followed side critically anyway.

Also cited on this issue (20)

Case	Cited	Years
State v. Morris green kan · 2014 2 sentences 2026The Edgar factors are not exclusive—rather, they provide "'viable benchmarks for judicial discretion.'" State v. Morris, 298 Kan. 1091, 1101 , 319 P.3d 539 (2014) (quoting State v. Bricker, 292 Kan. 239, 245 , 252 P.3d 118 [2011]). 2026The Edgar factors are not exclusive—rather, they provide "'viable benchmarks for judicial discretion.'" State v. Morris, 298 Kan. 1091, 1101 , 319 P.3d 539 (2014) (quoting State v. Bricker, 292 Kan. 239, 245 , 252 P.3d 118 [2011]).	4	2017–2026
State v. White green kan · 2009 2 sentences 2020State v. White, 289 Kan. 279, 284-85 , 211 P.3d 805 (2009). 2020State v. White, 289 Kan. 279, 284-85 , 211 P.3d 805 (2009).	2	2020–2020
Strickland v. Washington green scotus · 1984 2 sentences 2020The court stated, "The Edgar factors are, one, whether the defendant was represented by competent counsel, [two] whether the defendant was misled, coerced, mistreated or unfairly taken advantage of and, three, whether the plea was fairly and understandingly made." As to the first Edgar issue, which is the one relevant for this appeal, the court stated: "[To address the first factor,] I considered the two-prong test in Strickland v. Washington, 466 U.S. 668 , [ 104 S. Ct. 2052 , 80 L. 2020The court stated, "The Edgar factors are, one, whether the defendant was represented by competent counsel, [two] whether the defendant was misled, coerced, mistreated or unfairly taken advantage of and, three, whether the plea was fairly and understandingly made." As to the first Edgar issue, which is the one relevant for this appeal, the court stated: "[To address the first factor,] I considered the two-prong test in Strickland v. Washington, 466 U.S. 668 , [ 104 S. Ct. 2052 , 80 L.	2	2010–2020
State v. Newman green kan · 2020 2 sentences 2020State v. Newman, 311 Kan. 1215 , 1218-19, 457 P.3d 923 (2020); State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006). 2020State v. Newman, 311 Kan. 1215 , 1218-19, 457 P.3d 923 (2020); State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006).	2	2020–2020
State v. Hill green kan · 1990 2 sentences 2026State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006); State v. Hill, 247 Kan. 377, 385 , 799 P.2d 997 (1990) (discussing adoption of ABA standards for plea negotiations in State v. Byrd, 203 Kan. 45, 50-52 , 453 P.2d 22 [1969]). 2026State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006); State v. Hill, 247 Kan. 377, 385 , 799 P.2d 997 (1990) (discussing adoption of ABA standards for plea negotiations in State v. Byrd, 203 Kan. 45, 50-52 , 453 P.2d 22 [1969]).	1	2026–2026
State v. Byrd green kan · 1969 2 sentences 2026State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006); State v. Hill, 247 Kan. 377, 385 , 799 P.2d 997 (1990) (discussing adoption of ABA standards for plea negotiations in State v. Byrd, 203 Kan. 45, 50-52 , 453 P.2d 22 [1969]). 2026State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006); State v. Hill, 247 Kan. 377, 385 , 799 P.2d 997 (1990) (discussing adoption of ABA standards for plea negotiations in State v. Byrd, 203 Kan. 45, 50-52 , 453 P.2d 22 [1969]).	1	2026–2026
Flynn v. State green kan · 2006 2 sentences 2025Even so, Gomez points to the fact that the district court also 3 mentions Flynn v. State, 281 Kan. 1154, 1165 , 136 P.3d 909 (2006) and State v. Griffin, 279 Kan. 634, 649 , 112 P.3d 862 (2005) in support of his suggestion that the wrong legal standard was applied. 2025Even so, Gomez points to the fact that the district court also 3 mentions Flynn v. State, 281 Kan. 1154, 1165 , 136 P.3d 909 (2006) and State v. Griffin, 279 Kan. 634, 649 , 112 P.3d 862 (2005) in support of his suggestion that the wrong legal standard was applied.	1	2025–2025
State v. Edwards green kan · 2019 2 sentences 2025As the district court correctly explained, courts consider the Edgar factors when determining whether a defendant has 15 shown good cause to set aside a presentence guilty plea: "(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. Edwards, 309 Kan. 830 , 836, 440 P.3d 557 (2019) (citing Edgar, 281 Kan. at 36 ). 2025As the district court correctly explained, courts consider the Edgar factors when determining whether a defendant has 15 shown good cause to set aside a presentence guilty plea: "(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. Edwards, 309 Kan. 830 , 836, 440 P.3d 557 (2019) (citing Edgar, 281 Kan. at 36 ).	1	2025–2025
State v. Griffin green kan · 2005 2 sentences 2025Even so, Gomez points to the fact that the district court also 3 mentions Flynn v. State, 281 Kan. 1154, 1165 , 136 P.3d 909 (2006) and State v. Griffin, 279 Kan. 634, 649 , 112 P.3d 862 (2005) in support of his suggestion that the wrong legal standard was applied. 2025Even so, Gomez points to the fact that the district court also 3 mentions Flynn v. State, 281 Kan. 1154, 1165 , 136 P.3d 909 (2006) and State v. Griffin, 279 Kan. 634, 649 , 112 P.3d 862 (2005) in support of his suggestion that the wrong legal standard was applied.	1	2025–2025
Dusky v. United States green scotus · 1960 2 sentences 2024Harrison argues that rather than applying the good cause standard to the third Edgar factor, the district court erroneously applied the more stringent constitutional competency to stand trial standard, as provided in Dusky v. United 13 States, 362 U.S. 402 , 80 S. Ct. 788 , 4 L. 2024Harrison argues that rather than applying the good cause standard to the third Edgar factor, the district court erroneously applied the more stringent constitutional competency to stand trial standard, as provided in Dusky v. United 13 States, 362 U.S. 402 , 80 S. Ct. 788 , 4 L.	1	2024–2024
State v. Ingham green kan · 2018 2 sentences 2024State v. Ingham, 308 Kan. 1466 , 1469, 430 P.3d 931 (2018). 7 Patton argues that when the district court denied his postsentence request to withdraw his no-contest pleas, it abused its discretion for two reasons: (1) because the district court lacked a factual basis to accept his plea to aggravated kidnapping and (2) because the Edgar factors leaned in his favor. 2024State v. Ingham, 308 Kan. 1466 , 1469, 430 P.3d 931 (2018). 7 Patton argues that when the district court denied his postsentence request to withdraw his no-contest pleas, it abused its discretion for two reasons: (1) because the district court lacked a factual basis to accept his plea to aggravated kidnapping and (2) because the Edgar factors leaned in his favor.	1	2024–2024
State v. Ebaben green kan · 2012	1	2018–2018
State v. Rodriguez green kan · 1994	1	2017–2017
State v. Denmark-Wagner green kan · 2011	1	2017–2017
State v. Bey green kan · 2001	1	2017–2017
In Re the Estate of Newland green kan · 1986	1	2015–2015
State v. Edgar green kanctapp · 2011	1	2013–2013
Edgar v. State green kanctapp · 2009	1	2012–2012
State v. Ford green kanctapp · 1996	1	2012–2012
State v. Shaw green kan · 1996	1	2006–2006

Statutes the citing opinions construe

KS § K.S.A. § 22-3210 (97) KS § K.S.A. § 60-1507 (21) KS § K.S.A. § 22-3602 (11) KS § K.S.A. § 21-6804 (8) KS § K.S.A. § 22-4901 (7) KS § K.S.A. § 20-3018 (6) KS § K.S.A. § 22-3504 (6) KS § K.S.A. § 21-6801 (5) KS § K.S.A. § 21-4720 (4) KS § K.S.A. § 21-6815 (4) KS § K.S.A. § 22-3601 (4) KS § K.S.A. § 60-2101 (4)

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.

Where else courts name it

KS 104 (2006–2026) AL 3 (1985–2013) UT 2 (2017–2017)

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.

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