State v. Buford, 405 P.3d 1194

In 1990 Tyrence Lee Buford pled guilty to felony murder and was sentenced to life imprisonment under K.S.A. 21-4501(a).
Buford has appeared before the Kansas Parole Board multiple times and was repeatedly denied parole; his most recent denial was alleged in 2014.
In November 2014 Buford filed a pro se K.S.A. 22-3504 motion to correct an illegal sentence, arguing each parole denial amounted to a new, illegal sentence.
Buford contended the parole denials relied on an improper classification of his pre-1993 prior conviction under the Kansas Sentencing Guidelines, raising Sixth Amendment concerns (citing Descamps and Dickey).
The district court summarily denied the motion, finding Buford received a proper life sentence; Buford appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a parole denial constitutes an illegal "sentence" under K.S.A. 22-3504	Buford: each parole "pass" constituted a new sentence increasing his penalty based on misclassified prior conviction	State: parole denials are not sentences; underlying sentence remains life imprisonment	The denial of parole is not a sentence; 22-3504 does not apply; district court affirmed

Descamps v. United States, 570 U.S. 254 (Supreme Court rule on Sixth Amendment and prior-conviction enhancements)
State v. Dickey, 301 Kan. 1018 (Kan. 2015) (application of Descamps principles in Kansas)
Gilmore v. Kansas Parole Board, 243 Kan. 173 (prisoner has no liberty interest in parole grant)
State v. Gilbert, 299 Kan. 797 (standard of review for summary denial of 22-3504 motions)
State v. Gray, 303 Kan. 1011 (definition of an illegal sentence under 22-3504)
Battrick v. State, 267 Kan. 389 (requirement to exhaust administrative remedies before 60-1501 relief)