State v. Hall, 257 P.3d 263

Hall pleaded guilty to six felonies and one misdemeanor in Shawnee County; charges included aggravated battery, two counts of attempted murder in the first degree, conspiracy to commit aggravated robbery, murder in the first degree, aggravated indecent liberties with a child, and criminal desecration of a body, arising from two separate incidents.
Initial competency hearing (Dec 5, 2007) found Hall incompetent; committed to Larned State Security Hospital for evaluation.
Forensic psychologist Dr. Landers later determined Hall competent to stand trial (May 23, 2008); Hall discharged May 28, 2008.
A second competency hearing (June 18, 2008) found Hall competent to stand trial; evaluation results not contested at sentencing.
Hall pleaded guilty one day after a favorable-but-nunc-pro-tunc evaluation, with plea agreement stating no sentencing agreements and outlining ranges; murder in the first degree labeled as an off-grid life sentence.
Sentences imposed consecutively for all counts; Hall did not move to withdraw his plea in the district court and challenged on appeal the plea competence and failure to inform of maximum penalty for first-degree murder.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hall may appeal a conviction resulting from a guilty plea.	Hall.	State argues lack of jurisdiction due to direct appeal from guilty plea.	Appeal dismissed for lack of jurisdiction.
Whether Hall was competent to enter his guilty plea and whether the court properly advised him about the maximum penalty for first-degree murder.	Hall asserts incompetence to plead and misadvisement on maximum penalty.	State contends competency issue not properly preserved; plea transcripts show adequate advisement.	Competency issue not reviewable on direct appeal; misadvisement claim rejected on merits due to timing and evidence.
Whether the sentencing court erred by sentencing Hall given an alleged incompetent condition.	Hall argues incompetence to be sentenced.	State contends no basis from record to conclude incompetence at sentencing.	Sentence affirmed; Hough's competency findings supported by sentencing record.

State v. Campbell, 273 Kan. 414 (2002) (waiver of appeal rights in plea agreements; lack of jurisdiction on direct appeal from guilty pleas)
State v. Williams, 37 Kan. App. 2d 404 (2007) (defendant may not appeal conviction without first moving to withdraw plea; jurisdictional bar)
State v. Harned, 281 Kan. 1023 (2006) (abuse-of-discretion review for withdrawal of plea; competency-related issues)
State v. Muriithi, 273 Kan. 952 (2002) (abuse-of-discretion standard; appellate review of plea withdrawal)
State v. Bey, 270 Kan. 544 (2001) (statutory framework for withdrawal of guilty plea; competency considerations)
State v. Shopteese, 283 Kan. 331 (2007) (due process concerns where competency or related rights are implicated)
State v. Davis, 281 Kan. 169 (2006) (competency determinations and suspension of proceedings; application limited to its facts)