State v. Edwards, 440 P.3d 557

Steven Edwards was charged with two counts of capital murder and related offenses for two 2014 killings; public defenders were appointed after he was found indigent.
Edwards twice complained about counsel (lack of discovery access, counsel urging plea, and an alleged sexual relationship between him and a defense attorney); the court denied his motion for new counsel.
Edwards pleaded guilty to two counts of felony murder, aggravated burglary, and aggravated robbery as part of a plea agreement; at the plea hearing he expressed limited satisfaction with counsel but affirmed the pleas were voluntary.
Two weeks later Edwards moved pro se to withdraw his pleas, alleging coercion, ineffective representation, and sexual misconduct by counsel; new counsel pursued the motion asserting good cause under State v. Edgar.
The district court held a hearing, credited defense counsel, found no coercion or incompetence, denied withdrawal, and sentenced Edwards to concurrent life terms plus additional months; the court orally ordered lifetime postrelease supervision and waived BIDS fees, though the journal entry mistakenly assessed a $100 BIDS administrative fee.
On appeal to the Kansas Supreme Court Edwards challenged denial of plea withdrawal, the legality of lifetime postrelease supervision, and the journal-entry fee inconsistency.

Issue	Edwards' Argument	State's Argument	Held
Whether the district court abused discretion by denying motion to withdraw guilty plea	Plea was coerced by counsel and mother; counsel ineffective and engaged in sexual misconduct	District court correctly found Edgar factors not met; plea was voluntary and counsel competent	Denial affirmed — no abuse of discretion; Edgar factors not satisfied
Whether court could impose lifetime postrelease supervision for off-grid life sentence (felony murder)	Edwards argued postrelease supervision was improper	State conceded error	Vacated — lifetime postrelease supervision invalid for off-grid life sentence; remand to impose lifetime parole
Whether the journal entry must be corrected regarding BIDS administrative fee	Edwards asserted the fee was waived orally and journal entry is mistaken	State conceded the bench ruling controls and entry is clerical error	Journal entry to be corrected nunc pro tunc to reflect waiver of BIDS fees
Whether sexual-misconduct allegation warranted plea withdrawal	Edwards alleged sexual relationship with counsel compromised representation	Court found allegations not credible; defense counsel credible	Allegation insufficient to show coercion or incompetence; does not justify withdrawal

State v. Edgar, 281 Kan. 30, 127 P.3d 986 (2006) (sets three-factor test for pre-sentencing plea withdrawal)
State v. Summers, 293 Kan. 819, 272 P.3d 1 (2012) (sentencing court may not order postrelease supervision with an off-grid life sentence)
State v. Ross, 295 Kan. 1126, 289 P.3d 76 (2012) (off-grid life sentence should be followed by lifetime parole, not postrelease supervision)
State v. Potts, 304 Kan. 687, 374 P.3d 639 (2016) (vacating improper lifetime postrelease supervision and instructing imposition of lifetime parole)
State v. Mason, 294 Kan. 675, 279 P.3d 707 (2012) (oral pronouncement controls over inconsistent journal entry; clerical errors correctable)
State v. DeAnda, 307 Kan. 500, 411 P.3d 330 (2018) (standard of review for plea-withdrawal rulings is abuse of discretion)
State v. Schaal, 305 Kan. 445, 383 P.3d 1284 (2016) (plea-withdrawal review and factors to consider)
State v. Schaefer, 305 Kan. 581, 385 P.3d 918 (2016) (courts may consider additional facts beyond Edgar factors when deciding plea-withdrawal motions)