State v. England, 245 P.3d 1076

England pled no contest to rape and attempted rape in 1993; rape occurred before the KSGA, attempted rape after the KSGA.
Rape sentence: 15 years to life; attempted rape sentence: 81 months, concurrent to rape.
In 2007–2008 England pursued a nunc pro tunc correction and challenged his criminal history score as uncounseled, seeking a different score, potentially altering his KSGA sentence.
Trial court denied the motion to correct an illegal sentence and the objection to criminal history, ruling England was not eligible for KSGA conversion and that the motions were successive.
On appeal, England argues the criminal history computation was incorrect and that the rape sentence should have been converted under the KSGA; the State argues mootness and lack of evidentiary basis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness of the criminal history challenge	England contends uncounseled misdemeanors should not be aggregated.	State argues adjustment has no practical effect; mootness.	Issue dismissed as moot.
Entitlement to conversion of the rape sentence to KSGA	England should have his rape sentence converted under KSGA due to uncounseled prior convictions.	England ineligible for conversion; no remedy.	Not entitled to conversion; remand for calculation not required.
Illegality of sentence for failure to compute KSGA sentence	Court failed to calculate the KSGA sentence for rape.	Failure to compute does not render sentence illegal.	Sentence not illegal; no remand needed.

State v. Gracey, 200 Kan. 252 (2009) (unlimited review on illegality; burden-shifting principles cited)
State v. Howard, 287 Kan. 686 (2008) (standard for evidentiary hearing on illegal sentence/motion to correct)
State v. Perez, 267 Kan. 543 (1999) (procedural and substantive considerations for corrections)
Swenson v. State, 284 Kan. 931 (2007) (standard for evidentiary basis in 60-1507 motions)
State v. Rupnick, 280 Kan. 720 (2005) (briefs and briefing requirements; waiver/abandonment considerations)
State v. Paul, 285 Kan. 658 (2008) (recording requirements; burden on appellant to furnish record)
State v. Cheeks, 263 Kan. 193 (1997) (remedy when guidelines calculation not done does not render sentence illegal)
State v. Aleman, 251 Kan. 940 (1992) (general principles on mootness and appellate review)
State v. Jones, 272 Kan. 674 (2001) (burden in postconviction challenge to criminal history)
State v. Patterson, 262 Kan. 481 (1997) (burden to show lack of counsel for prior convictions)
Bruner v. State, 277 Kan. 603 (2004) (pro se pleadings liberal construction)
Jackson v. State, 1 Kan. App. 2d 744 (1977) (pro se pleading treatment; recognition of liberal construction)