State v. Alderson, 299 Kan. 148

Alderson is serving life imprisonment for felony murder and aggravated battery.
The restitution order totaled $119,899.86 and was based on original sentencing calculations; it was not collected.
In 2009, Alderson received a notice demanding immediate payment of $150,903.74 from Municipal Services Bureau.
Alderson filed a pro se motion to be released from the restitution order on the basis of dormancy; district court denied summarily.
The district court treated restitution as not yet due, and the dormancy petition as premature.
The court held no enforceable restitution judgment existed; the advisory calculation served only for the Prisons Review Board.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is restitution enforceable while incarcerated?	Alderson argues restitution may be collected during incarceration under updated statutes.	State contends restitution cannot be enforced during incarceration based on older precedents.	Restitution cannot be enforced during incarceration; no enforceable judgment exists.
Did a valid restitution judgment ever become due or dormancy applies?	Alderson contends dormancy applies to preserve rights if no judgment exists.	State argues the judgment could become due later, or dormancy applies under statute.	No pending judgment; dormancy not triggered.
Did the district court err in treating the restitution order as advisory rather than enforceable?	Alderson claims the order was an enforceable judgment linked to parole conditions.	State argues it was advisory and could not become a dormant obligation.	District court correctly found no enforceable restitution judgment; advisory calculation not a judgment.

Puckett v. Bruce, 276 Kan. 59 (2003) (recognizes restitution can be collected from prison accounts under updated statutes)
State v. Robards, 31 Kan. App. 2d 1138 (2003) (older law on dormancy and restitution; later changes noted)
State v. DeHerrera, 251 Kan. 143 (1992) (restitution not payable while incarcerated under older rule)
State v. Bowers, 239 Kan. 417 (1986) (restitution/ sentence interplay in prior framework)
State v. McNaught, 238 Kan. 567 (1986) (early guidance on restitution in sentencing context)
State v. Clark, 298 Kan. 843 (2014) (parole conditions not set by sentencing court)
State v. Waggoner, 297 Kan. 94 (2013) (parole conditions responsibility clarified)
State v. Mason, 294 Kan. 675 (2012) (parole-related conditions and sentencing context)
State v. Hall, 297 Kan. 709 (2013) (judgment correct in result but based on incorrect reasoning)