State v. Jeffries, 304 Kan. 748

In 1986–87 Jeffries committed armed robberies; during one a clerk was killed. He pled guilty/nolo contendere to multiple aggravated robberies and felony murder and received a controlling sentence of life without parole for 30 years (indeterminate pre-1993 sentence).
The 1993 Kansas Sentencing Guidelines Act (KSGA) generally did not apply to crimes committed before July 1, 1993, but K.S.A. 21-4724 provided limited, specific exceptions allowing retroactive conversion for certain less-severe pre-1993 indeterminate sentences.
The Kansas Department of Corrections notified Jeffries he was ineligible for conversion because at least one conviction (aggravated robbery) would be a severity level 3 nondrug felony under the KSGA, and Jeffries did not appeal that administrative finding at the time.
After this court’s decision in State v. Murdock, Jeffries moved in 2014 to correct an illegal sentence, arguing Murdock’s reasoning meant aggravated robbery could not be treated as a KSGA severity level 3 for retroactivity purposes.
The district court summarily denied the motion; Jeffries appealed directly to the Kansas Supreme Court, which reviewed the legal issue de novo.

Issue	Jeffries' Argument	State's Argument	Held
Whether Murdock requires treating pre-1993 in-state aggravated robbery as not a KSGA severity level 3, making Jeffries eligible for retroactive conversion under K.S.A. 21-4724	Murdock shows ambiguity in comparing crimes across time; because severity-level classifications did not exist pre-1993, aggravated robbery cannot be used to deny conversion	K.S.A. 21-4724 is unambiguous: eligibility is determined by comparing pre-1993 crimes to law as of July 1, 1993; aggravated robbery would be level 3 and thus ineligible	Denied — Murdock is inapplicable; statute clearly compares pre-1993 acts to the law effective July 1, 1993, so Jeffries is ineligible for conversion

State v. Murdock, 299 Kan. 312 (interpretation of temporal reference for classifying out-of-state prior convictions; holding limited to K.S.A. 21-4711(e))
State v. Keel, 302 Kan. 560 (later decision overruling Murdock on related points)
State v. Roseborough, 263 Kan. 378 (retroactive conversion under KSGA is a legislative grace, not an entitlement)
State v. Williams, 291 Kan. 554 (temporal construction principle used in Murdock)
State v. Overman, 301 Kan. 704 (appellate court will affirm district court's correct result)