State v. Adams, 297 Kan. 665

Adams appeals district court denial of her K.S.A. 60-1507 claim alleging ineffective assistance of counsel and denial of her motion to withdraw her guilty plea in a consolidated case.
The State charged Adams with aggravated indecent liberties with a child, aggravated criminal sodomy, and sexual exploitation of a child; the complaint was amended to add a second count.
Authorities obtained a memory card with 50 photos of an 8-year-old child and two adults, identified Adams, her daughter S.A., and her boyfriend Noble; Adams confessed to acts with S.A. while Noble watched via webcam.
Eckelman negotiated a plea: Adams would plead guilty to aggravated indecent liberties with a child and testify against Noble; the State would dismiss other charges and Adams would be barred from filing a departure motion or contacting S.A. until she turns 18.
At the plea hearing, Adams was told she faced a life sentence with 25 years before parole eligibility; she pled guilty and the court accepted the plea.
Afterward Adams sought to remove Eckelman but was informed she would remain bound by the plea; sentencing under Jessica’s Law resulted in a hard 25‑life term; motion practice followed, including a 60-1507 claim and a motion to withdraw the plea, with an evidentiary hearing producing conflicting testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sixth Amendment requires withdrawal of plea	Adams argues Eckelman’s failures deprived Sixth Amendment rights.	Eckelman contends no prejudice despite alleged deficiencies.	No prejudice shown; no withdrawal required.
Whether 22-3210(d)(2) supports withdrawal to correct manifest injustice	Adams relies on ineffective assistance theory to withdraw plea.	Because Sixth Amendment claim fails, statute fails too.	Statutory relief denied; claim fails.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong ineffective assistance standard)
United States v. Cronic, 466 U.S. 648 (U.S. 1984) (narrow exceptions to Strickland for no prejudice showing)
Florida v. Nixon, 543 U.S. 175 (U.S. 2004) (cautionary note on rare Cronic-like claims)
State v. Qualls, 297 Kan. 61 (Kan. 2013) (appellate review limits credibility determinations)
State v. Bricker, 292 Kan. 239 (Kan. 2011) (prejudice inquiry in guilty-plea context)
State v. Carter, 270 Kan. 426 (Kan. 2000) (Cronic-like concerns and counsel performance)
Edgar v. State, 294 Kan. 828 (Kan. 2012) (treats application of Cronic in Kansas context)