State v. Castillo, 115504

Bonnie L. Castillo pleaded guilty to two counts of felony DUI under K.S.A. 2016 Supp. 8-1567 and received two consecutive 1-year jail terms plus mandatory 1-year postimprisonment supervision for each count.
Castillo had an extensive prior criminal history and admitted intoxication at arrest for both new offenses.
After serving her jail term(s), Castillo was released to supervised postimprisonment status and later submitted breath tests showing elevated BACs and missed other required tests.
The district court found Castillo violated her supervision, revoked her postimprisonment supervision, and remanded her to jail for the balance of the supervision period.
Castillo appealed, arguing the district court lacked jurisdiction to revoke postrelease/postimprisonment supervision and that only the Department of Corrections (or supervising agency) could revoke such release.
The appellate court treated Castillo’s argument as a subject-matter jurisdiction challenge, which can be raised at any time, and reviewed statutory construction and precedent to decide whether the district court retained authority.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court had jurisdiction to revoke Castillo’s postimprisonment/postrelease supervision and impose additional jail time	Castillo: The post-incarceration period is "postrelease supervision" governed by the KSGA and under the Secretary of Corrections; only that agency may revoke release	State: DUI statute is self-contained; district court retains authority to place offenders on community correctional or court services supervision and to revoke that supervision	The court held the district court retained jurisdiction to revoke postimprisonment supervision under K.S.A. 8-1567 and related statutes

State v. Key, 298 Kan. 315 (2013) (DUI statute is a self-contained habitual criminal statute)
State v. Reese, 300 Kan. 650 (2014) (DUI sentencing not governed by KSGA; DUI statute controls)
State v. Anthony, 274 Kan. 998 (2002) (district court lacks jurisdiction to modify a felony DUI sentence except as provided by statute)
Jahnke v. Blue Cross & Blue Shield of Kan., Inc., 51 Kan. App. 2d 678 (2015) (defining subject-matter jurisdiction)
State v. Sales, 290 Kan. 130 (2010) (subject-matter jurisdiction may be raised at any time)
Phillpot v. Shelton, 19 Kan. App. 2d 654 (1994) (inmate on postrelease supervision remains in legal custody of the Secretary of Corrections)
State v. Urban, 291 Kan. 214 (2010) (statutory language should be given its plain meaning)
Martin v. Kansas Parole Bd., 292 Kan. 336 (2011) (legislatures presumed to intend purposeful change when statutes are revised)