State v. LaGrange, 279 P.3d 105

LaGrange was convicted in 1994 of aggravated battery and sentenced to prison.
He was released from prison on the aggravated battery sentence in 2004.
In 2007 he was charged with criminal possession of a firearm under K.S.A. 21-4204(a)(4)(A).
The district court held the 10-year firearm ban began on his 2004 release date; LaGrange argued it began on the 1994 conviction date.
The Court of Appeals affirmed the district court’s interpretation.
The Kansas Supreme Court granted review to resolve the interpretive questions about the statute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does the 10-year ban start under 21-4204(a)(4)(A)?	LaGrange argues the ban runs from the 1994 conviction date.	LaGrange contends the 10-year period begins at release from prison, not conviction.	Ban starts at prison release date; not from conviction.
What is the meaning of the 'out-of-state felony' and 'released from imprisonment' phrases?	Out-of-state and listed felonies should be treated differently; release from prison applies only to listed felonies.	The phrases together cover both listed and substantially similar out-of-state felonies, staying the clock during imprisonment.	The statute ties both listed Kansas felonies and substantially similar out-of-state felonies to the 10-year period, with the clock starting on release from prison or conviction accordingly.

State v. Arnett, 290 Kan. 41 (2010) (statutory interpretation is a question of law reviewed de novo)
State v. Urban, 291 Kan. 214 (2010) (interpretation starts with plain language and legislative intent)
State v. Jackson, 291 Kan. 34 (2010) (rule of lenity limited by sensible legislative design)
State v. Trautloff, 289 Kan. 793 (2009) (recognizes presumption against useless or meaningless statutes)