State v. Jolly, 249 P.3d 421

Jolly pleaded guilty to rape, an off-grid felony under Jessica's Law, with a mandatory life sentence and 25-year minimum.
The district court departed from the life sentence to 300 months, plus lifetime postrelease supervision and lifetime electronic monitoring.
Jolly appealed, challenging both the 300-month term and the electronic-monitoring condition as improper under statute and procedure.
The plea record showed a 12-year-old victim; Jolly admitted to extensive sexual acts and later minimized his conduct at sentencing.
The court acknowledged some substantial and compelling reasons but did not follow proper steps to depart under Jessica's Law and the Kansas Sentencing Guidelines Act (KSGA).
This Court held the 300-month sentence and the electronic-monitoring condition were illegal and vacated/remanded for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court follow statutory authority to impose 300 months?	Jolly: improper dual departures; illegal elevation from guidelines.	State: remand for findings needed due to unclear record.	Sentence illegal; vacate and remand for proper resentencing.
Was lifetime electronic monitoring a valid sentencing condition?	Monitored condition may be proper under parole but not sentencing.	State argued it follows from Jessica's Law and parole framework.	Electronic monitoring improperly imposed; vacate/remand.

State v. Gracey, 288 Kan. 252 (2009) (departs to guidelines when substantial and compelling reasons exist; stepwise process)
State v. Ballard, 289 Kan. 1000 (2009) (illegal sentence if not conforming to statutory provisions; framework for departures)