State v. Baker, 429 P.3d 240

Valerie S. Baker committed serial embezzlement from three employers; pleaded guilty in 2012 to two forgery (severity level 8) counts and one theft (severity level 7) count arising from the second employer and was sentenced with probation and restitution obligations.
At sentencing the court pronounced a 24‑month probation overall but the journal entry specified 18 months probation for each forgery and 24 months for the theft; forgery probations thus were capped at 18 months by statute unless additional findings were made (none were).
Baker completed the 18‑month forgery probations (around Dec. 2013) before the State sought to revoke probation for nonpayment of restitution in May 2014 and long before her 2016 probation revocation based on a later embezzlement.
The district court, treating the case as having a unitary 24‑month probation, revoked probation in 2017 and ordered Baker to serve consecutive prison terms on both the forgery and theft convictions, producing a 37‑month term.
On appeal Baker argued she had completed the forgery probations and thus could not be sent to prison on those convictions; the State argued the multiple‑conviction statute allowed revocation to trigger consecutive service of all prison sentences.

Issue	Plaintiff's Argument (Baker)	Defendant's Argument (State)	Held
Whether court could revoke and impose prison terms on forgery convictions after Baker had completed the 18‑month forgery probations but remained on longer probation for the theft conviction	Baker: forgery probations were distinct, capped at 18 months, and had expired before any timely revocation; only theft sentence remained active	State: K.S.A. 21‑6819(b)(8) permits that upon revocation the offender "shall serve the prison sentences consecutively," implying revocation of the case can trigger service of all sentences	Court: Reversed revocation as to forgery convictions and vacated those prison sentences; only theft sentence could be executed because forgery probations had expired

State v. Turner, 293 Kan. 1085, 272 P.3d 19 (statutory construction reviewed de novo)
State v. Coman, 294 Kan. 84, 273 P.3d 701 (rule of lenity requires construing criminal statutes in favor of defendants)
State v. Barlow, 303 Kan. 804, 368 P.3d 331 (application of lenity in Kansas criminal law)
State v. Bennett, 51 Kan. App. 2d 356, 347 P.3d 229 (questions of law where facts undisputed)
In re Estate of Rickabaugh, 51 Kan. App. 2d 902, 358 P.3d 859 (in pari materia canon calls for harmonizing related statutes)