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110 Kansas opinions name it 2 courts 2006–2026 60 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 sentences2026Generally, district courts consider three factors—what we often describe as the Edgar factors after State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006)—when deciding whether a defendant has shown good cause to withdraw a plea. 2026Generally, district courts consider three factors—what we often describe as the Edgar factors after State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006)—when deciding whether a defendant has shown good cause to withdraw a plea. | 18 | 76 |
State v. Fraziergreen2 sentences2023While the Edgar factors establish "viable benchmarks" for the district court when exercising its discretion, "it is important to note that courts 'should not ignore other [non-Edgar] factors impacting a plea withdrawal that might exist in a particular case.'" Frazier, 311 Kan. at 381 (quoting State v. Shaefer, 305 Kan. 581 , Syl. ¶ 2, 588, 385 P.3d 918 [2016]). 2023While the Edgar factors establish "viable benchmarks" for the district court when exercising its discretion, "it is important to note that courts 'should not ignore other [non-Edgar] factors impacting a plea withdrawal that might exist in a particular case.'" Frazier, 311 Kan. at 381 (quoting State v. Shaefer, 305 Kan. 581 , Syl. ¶ 2, 588, 385 P.3d 918 [2016]). | 8 | 17 |
State v. Aguilargreen2 sentences2026But see Bilbrey, 317 Kan. at 62 (explaining the Edgar factors "should not be applied mechanically and to the exclusion of other factors"); State v. Aguilar, 290 Kan. 506, 512 , 231 P.3d 563 (2010) (describing the Edgar factors as "viable benchmarks"). 2026But see Bilbrey, 317 Kan. at 62 (explaining the Edgar factors "should not be applied mechanically and to the exclusion of other factors"); State v. Aguilar, 290 Kan. 506, 512 , 231 P.3d 563 (2010) (describing the Edgar factors as "viable benchmarks"). | 6 | 44 |
State v. Williamsgreen2 sentences2026See Garcia, 295 Kan. at 63 (district court not confined to Edgar factors); State v. Williams, 290 Kan. 1050, 1054 , 236 P.3d 512 (2010) (all of the Edgar factors need not favor defendant; court may consider other circumstances). 2026See Garcia, 295 Kan. at 63 (district court not confined to Edgar factors); State v. Williams, 290 Kan. 1050, 1054 , 236 P.3d 512 (2010) (all of the Edgar factors need not favor defendant; court may consider other circumstances). | 6 | 9 |
State v. Schowgreen2 sentences2026See 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. Garciagreen2 sentences2026State v. Rayton, 321 Kan. 677 , Syl. ¶ 3, 583 P.3d 898 (2026); State v. Garcia, 295 Kan. 53 , 62- 63, 283 P.3d 165 (2012) (noting that these considerations—commonly known as the 6 Edgar factors—establish a sound benchmark for determining good cause); State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006). 2026State v. Rayton, 321 Kan. 677 , Syl. ¶ 3, 583 P.3d 898 (2026); State v. Garcia, 295 Kan. 53 , 62- 63, 283 P.3d 165 (2012) (noting that these considerations—commonly known as the 6 Edgar factors—establish a sound benchmark for determining good cause); State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006). | 5 | 7 |
State v. Bilbreygreen2 sentences2026But see Bilbrey, 317 Kan. at 62 (explaining the Edgar factors "should not be applied mechanically and to the exclusion of other factors"); State v. Aguilar, 290 Kan. 506, 512 , 231 P.3d 563 (2010) (describing the Edgar factors as "viable benchmarks"). 2026But see Bilbrey, 317 Kan. at 62 (explaining the Edgar factors "should not be applied mechanically and to the exclusion of other factors"); State v. Aguilar, 290 Kan. 506, 512 , 231 P.3d 563 (2010) (describing the Edgar factors as "viable benchmarks"). | 3 | 5 |
State v. Johnsongreen2 sentences2025These 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). | 3 | 5 |
State v. Fritzgreen2 sentences2026I would find both determinations by the district court were legal errors. 24 First, while the Edgar factors provide "viable benchmarks" in determining whether a defendant has shown good cause, the Supreme Court has repeatedly emphasized that "[t]hese factors should not, however, be applied mechanically and to the exclusion of other factors." State v. Fritz, 299 Kan. 153, 154 , 321 P.3d 763 (2014); see also State v. Schaefer, 305 Kan. 581 , Syl. ¶ 2, 385 P.3d 918 (2016) (Courts "should not ignore other [non-Edgar] factors impacting a plea withdrawal that might exist in a particular case."). 2026I would find both determinations by the district court were legal errors. 24 First, while the Edgar factors provide "viable benchmarks" in determining whether a defendant has shown good cause, the Supreme Court has repeatedly emphasized that "[t]hese factors should not, however, be applied mechanically and to the exclusion of other factors." State v. Fritz, 299 Kan. 153, 154 , 321 P.3d 763 (2014); see also State v. Schaefer, 305 Kan. 581 , Syl. ¶ 2, 385 P.3d 918 (2016) (Courts "should not ignore other [non-Edgar] factors impacting a plea withdrawal that might exist in a particular case."). | 2 | 15 |
State v. DeAndagreen2 sentences2022While 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). 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). | 2 | 6 |
State v. Freemangreen2 sentences2021See 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. 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. 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. Andersongreen2 sentences2016Aguilar, 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. Greengreen2 sentences2014Edgar, 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. Brickergreen2 sentences2026The 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. Woodringgreen2 sentences2023State 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-Medinagreen2 sentences2022Our 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. Adamsgreen2 sentences2022See State v. Adams, 311 Kan. 569 , 575, 465 P.3d 176 (2020); State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006). 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. Espinozagreen2 sentences2026Espinoza, 319 Kan. at 658-59. 2026Espinoza, 319 Kan. at 658-59. | 1 | 1 |
State v. Unruhgreen1 sentence2026The Unruh court, 320 Kan. at 264, citing State v. Allen, 314 Kan. 280 , Syl. ¶ 2, 497 P.3d 566 (2021), noted that in order for the court to consider addressing an unpreserved issue, the unpreserved issue must be amenable to resolution on appeal. | 1 | 1 |
| State v. Meggersongreen | 1 | 1 |
| State v. Shieldsgreen | 1 | 1 |
| State v. Arnettgreen | 1 | 1 |
| State v. Mosesgreen | 1 | 1 |
| State v. WICKENgreen | 1 | 1 |
| Wirt v. Esreygreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
State v. Aguilargreen2 sentences2026But see Bilbrey, 317 Kan. at 62 (explaining the Edgar factors "should not be applied mechanically and to the exclusion of other factors"); State v. Aguilar, 290 Kan. 506, 512 , 231 P.3d 563 (2010) (describing the Edgar factors as "viable benchmarks"). 2026But see Bilbrey, 317 Kan. at 62 (explaining the Edgar factors "should not be applied mechanically and to the exclusion of other factors"); State v. Aguilar, 290 Kan. 506, 512 , 231 P.3d 563 (2010) (describing the Edgar factors as "viable benchmarks"). | 1 | 44 |
State v. Bilbreygreen2 sentences2026But see Bilbrey, 317 Kan. at 62 (explaining the Edgar factors "should not be applied mechanically and to the exclusion of other factors"); State v. Aguilar, 290 Kan. 506, 512 , 231 P.3d 563 (2010) (describing the Edgar factors as "viable benchmarks"). 2026But see Bilbrey, 317 Kan. at 62 (explaining the Edgar factors "should not be applied mechanically and to the exclusion of other factors"); State v. Aguilar, 290 Kan. 506, 512 , 231 P.3d 563 (2010) (describing the Edgar factors as "viable benchmarks"). | 1 | 5 |
| Case | Cited | Years |
|---|---|---|
State v. Reu-El
green
2 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]). | 5 | 2020–2024 |
State v. Morris
green
2 sentences2026The 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. Newman
green
2 sentences2020State v. Newman, 311 Kan. 155 , 158-59, 457 P.3d 923 (2020); State v. Edgar, 281 Kan. 30 , 127 P.3d 986 (2006). 2020State v. Newman, 311 Kan. 155 , 158-59, 457 P.3d 923 (2020); State v. Edgar, 281 Kan. 30 , 127 P.3d 986 (2006). | 2 | 2020–2020 |
Strickland v. Washington
green
2 sentences2020The 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. Ed. 2d 674 (1984)]. 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. Ed. 2d 674 (1984)]. | 2 | 2010–2020 |
State v. White
green
2 sentences2020State 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 |
State v. Hill
green
2 sentences2026State 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
2 sentences2026State 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. Allen
green
2 sentences2026The Unruh court, 320 Kan. at 264, citing State v. Allen, 314 Kan. 280 , Syl. ¶ 2, 497 P.3d 566 (2021), noted that in order for the court to consider addressing an unpreserved issue, the unpreserved issue must be amenable to resolution on appeal. 2026The Unruh court, 320 Kan. at 264, citing State v. Allen, 314 Kan. 280 , Syl. ¶ 2, 497 P.3d 566 (2021), noted that in order for the court to consider addressing an unpreserved issue, the unpreserved issue must be amenable to resolution on appeal. | 1 | 2026–2026 |
State v. Rayton
green
2 sentences2026State v. Rayton, 321 Kan. 677 , Syl. ¶ 3, 583 P.3d 898 (2026); State v. Garcia, 295 Kan. 53 , 62- 63, 283 P.3d 165 (2012) (noting that these considerations—commonly known as the 6 Edgar factors—establish a sound benchmark for determining good cause); State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006). 2026State v. Rayton, 321 Kan. 677 , Syl. ¶ 3, 583 P.3d 898 (2026); State v. Garcia, 295 Kan. 53 , 62- 63, 283 P.3d 165 (2012) (noting that these considerations—commonly known as the 6 Edgar factors—establish a sound benchmark for determining good cause); State v. Edgar, 281 Kan. 30, 36 , 127 P.3d 986 (2006). | 1 | 2026–2026 |
Flynn v. State
green
2 sentences2025Even 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. Griffin green | 1 | 2025–2025 |
| State v. Edwards green | 1 | 2025–2025 |
| Dusky v. United States green | 1 | 2024–2024 |
| State v. Ingham green | 1 | 2024–2024 |
| State v. Ebaben green | 1 | 2018–2018 |
| State v. Rodriguez green | 1 | 2017–2017 |
| State v. Bey green | 1 | 2017–2017 |
| State v. Denmark-Wagner green | 1 | 2017–2017 |
| In Re the Estate of Newland green | 1 | 2015–2015 |
| State v. Edgar green | 1 | 2013–2013 |
| State v. Ford yellow | 1 | 2012–2012 |
| Edgar v. State green | 1 | 2012–2012 |
| State v. Shaw green | 1 | 2006–2006 |
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.