State v. Antrim, 279 P.3d 110

Antrim pled no contest to three counts of aggravated indecent liberties with a child; the State dismissed three rape counts and recommended life with a 25-year mandatory minimum on each count, to run concurrently.
The plea agreement stated Antrim could seek any legally permissible sentence, but the State would oppose that effort.
At sentencing, Antrim moved to depart from the mandatory minimum; a psychologist testified about low reoffense risk and intra-family victim recidivism.
The prosecutor argued for adherence to the plea and to concurrent sentencing, and the court was asked to combine opposing arguments with the State’s recommendations.
The court imposed consecutive life sentences with a 25-year minimum on each count, denied departure, and later reference to lifetime electronic monitoring appeared in the journal entry.
The issue of lifetime electronic monitoring was later identified as outside the district court’s authority and led to a remand for a nunc pro tunc deletion of that reference.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Breach of plea agreement	Antrim claims the State breached by arguing against concurrent sentencing	State asserts it complied by endorsing the negotiated sentence and opposing departures	No breach; State complied with the plea terms and opposed departures within the agreement.
Parole eligibility	Antrim seeks parole after 20 years under 22-3717(b)(2)	Antrim remains eligible only after the mandatory 25-year term under 21-4643	District court did not err; parole eligibility follows the mandatory 25-year term per Hyche rule.
Lifetime electronic monitoring	Lifetime monitoring imposed in journal entry exceeds district court authority	Monitoring is governed by the parole board, not the district court; journal entry error	Remand for nunc pro tunc deletion of the monitoring reference; other sentence components affirmed.

State v. Woodward, 288 Kan. 297 (2009) (prosecutor may argue overcoming defense while honoring plea)
State v. Foster, 39 Kan. App. 2d 380 (2008) (distinguishes when a plea is breached by the State’s remarks)
State v. Hyche, 293 Kan. 602 (2011) (parole eligibility for off-grid life sentence; 25-year rule applies)
State v. Cash, 293 Kan. 326 (2011) (parole eligibility overlap in statutes acknowledged)
State v. Duong, 292 Kan. 824 (2011) (parole/monitoring authority debate; district court limitations)
State v. Jolly, 291 Kan. 842 (2011) (parole conditions outside district court jurisdiction)