State v. Carter, 419 P.3d 55

Tabitha Carter robbed a Wichita Dollar General, wearing a clown mask and taking $3,440; she displayed a Taser during the incident.
Two employees, Sanders (the named victim) and Reyes, complied after perceiving a weapon; hands were raised after the Taser was revealed.
A jury convicted Carter of aggravated robbery; district court sentenced her to 36 months and found she had used "a dangerous weapon," triggering the Kansas Offender Registration Act registration requirement.
Carter appealed both the sufficiency of the evidence for aggravated robbery and the district court’s finding that she had "used a deadly weapon" for registration purposes.
The Court of Appeals affirmed the aggravated-robbery conviction (applying the subjective test for "dangerous weapon") but vacated the registration requirement (holding the Registration Act requires an objective finding of a "deadly weapon").

Issue	Plaintiff's Argument (State)	Defendant's Argument (Carter)	Held
Sufficiency of evidence for aggravated robbery (was Carter "armed with a dangerous weapon" contemporaneous with taking property?)	Video and witness testimony show Carter displayed a Taser and victims reasonably perceived it as dangerous; display was contemporaneous with taking control of money.	Taser is not truly dangerous and was shown only after money was already in bag, making the taking complete (the offense should be theft).	Affirmed: jury could reasonably find the Taser appeared dangerous to victim and was displayed contemporaneously with the taking, supporting aggravated robbery.
Whether Carter "used a deadly weapon" for purposes of the Kansas Offender Registration Act (K.S.A. 22-4902)	The Taser should qualify for registration purposes consistent with precedents treating perceived dangerousness as sufficient.	"Deadly weapon" under the Registration Act is an objective term requiring the weapon, as used, be likely to produce death or serious bodily injury; no evidence showed the Taser was used or likely to cause death here.	Vacated registration: Registration Act requires an objective finding of a deadly weapon (likely to cause death or serious injury); no evidence showed Carter’s Taser met that standard.

State v. Colbert, 244 Kan. 422 (1989) (subjective test: weapon that appears dangerous to victim can elevate robbery to aggravated robbery)
State v. Davis, 227 Kan. 174 (1980) (starter pistol held a "dangerous weapon" under subjective test)
State v. Prince, 227 Kan. 137 (1980) (unloaded BB pistol treated as dangerous under subjective test)
State v. Bateson, 266 Kan. 238 (1998) (theft vs. robbery: force or threat must precede or be contemporaneous with taking)
State v. Dean, 250 Kan. 257 (1992) (taking not complete when defendant still exercising control; display of weapon can support aggravated robbery)
State v. Franklin, 44 Kan. App. 2d 156 (2010) (Court of Appeals applied subjective test under Registration Act; panel disagreed with that approach)
State v. Hanks, 236 Kan. 524 (1985) (definition of "deadly weapon" as likely to produce death or serious bodily injury under aggravated-battery context)
State v. Marinelli, 307 Kan. 768 (2018) (noted possible asymmetry between weapon characterizations for criminal conviction and registration; courts should be alert to distinction)