State v. Martin, 114921

In 1986 a jury convicted Frederick J. Martin of first-degree felony murder, aggravated kidnapping, and unlawful possession of a firearm for a 1985 killing.
Martin received consecutive life sentences for felony murder and aggravated kidnapping, and 3–10 years for the firearm offense (concurrent with the kidnapping life term).
Martin repeatedly challenged being convicted and sentenced for both the felony murder and the underlying aggravated kidnapping, arguing multiplicity/double jeopardy.
He raised the claim on direct appeal and in numerous postconviction proceedings and motions to correct an illegal sentence; prior courts rejected the claim.
In the underlying district-court motion before this appeal, the judge summarily denied Martin’s motion to correct an illegal sentence; Martin argued the judge’s findings were insufficient for meaningful review.
The Kansas Supreme Court reviewed the record, concluded the district court adequately addressed the claim, found no reversible error, and summarily affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether convictions and consecutive sentences for both felony murder and the underlying aggravated kidnapping violate double jeopardy/multiplicity	State: Charges and convictions were proper; prior rulings uphold this approach	Martin: Court lacked jurisdiction to impose multiple, consecutive convictions/sentences for the underlying felony and felony murder	Affirmed: No reversible error; prior and current review reject multiplicity/double jeopardy challenge
Whether the district court made sufficient factual findings when summarily denying the motion to correct an illegal sentence	State: Summary denial was adequate given record and prior rulings	Martin: Judge’s findings were insufficient for meaningful appellate review	Held: Findings and record adequately addressed the challenge; summary denial affirmed
Whether Martin’s repeated filings are barred by res judicata or are frivolous	State: Prior final rulings and procedural bars apply	Martin: Continues to reassert same substantive claim	Held: Prior decisions preclude relitigation; appeal deemed frivolous for summary affirmance
Whether summary disposition under K.S. Ct. Rule 7.042 was appropriate	State: Rule permits summary affirmation when no reversible error appears and appeal is frivolous	Martin: Implicitly contests sufficiency of review	Held: Rule 7.042 applied; case summarily affirmed

State v. Martin, 241 Kan. 732 (1987) (direct appeal rejecting double jeopardy challenge to convictions for felony murder and underlying felony)
State v. Martin, 294 Kan. 638 (2012) (motion to correct illegal sentence; multiplicity challenge barred by res judicata)
State v. King, 297 Kan. 955 (2013) (discusses multiplicity and the principal danger of double jeopardy)