State v. Medina
384 P.3d 26
Kan. Ct. App.2016Background
- Medina, prosecuted as an adult for offenses committed while under 18, pled no contest to aggravated criminal sodomy arising from sexual acts with his younger sister and received 165 months' imprisonment plus mandatory lifetime postrelease supervision (PRS); he appealed only the PRS portion.
- Kansas law (K.S.A. 2015 Supp. 22-3717) required lifetime PRS for aggravated criminal sodomy.
- Medina argued mandatory lifetime PRS for juvenile sex offenders is categorically cruel and unusual under the Eighth Amendment; he also raised a Kansas Constitution § 9 challenge (which the court declined to address).
- The State conceded the Eighth Amendment issue could be raised on appeal but defended the constitutionality of lifetime PRS and argued the Kansas § 9 claim was fact-intensive and unpreserved.
- The Court of Appeals followed Kansas Supreme Court precedent in Dull, concluding Dull’s rationale extends categorically to all juvenile sex-offense convictions and vacated only the lifetime PRS portion of Medina’s sentence, remanding for resentencing without any PRS term.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandatory lifetime PRS for juveniles convicted of sex offenses violates the Eighth Amendment (categorical proportionality) | Medina: Lifetime PRS is categorically disproportionate for juvenile sex offenders under Graham; juveniles have diminished culpability and PRS is severe and not justified by penological goals | State: Dull is distinguishable (less serious offense there) and no national consensus against lifetime PRS; if Dull applied broadly it was wrongly decided | Court: Applying Dull, mandatory lifetime PRS is categorically unconstitutional for all juveniles convicted of sex offenses; vacated lifetime PRS portion and remanded for resentencing without PRS |
| Whether Medina’s Kansas Constitution § 9 claim may be considered on appeal | Medina: § 9 claim is a pure legal question determinative of the case and can be raised on appeal | State: § 9 claim involves factual inquiries and is therefore unpreserved or inadequately briefed | Held: § 9 challenge requires fact‑intensive Freeman analysis and is not considered on appeal |
| Whether Dull is limited to aggravated indecent liberties or applies to all juvenile sex offenses | Medina: Dull’s reasoning about juvenile culpability and penological goals is not crime-specific and thus extends to all juvenile sex offenses | State: Dull concerned a less serious, nonpenetrative offense and is thus distinguishable | Held: Dull’s reasoning is not crime‑specific; precedent controls and applies categorically to juvenile sex offenders |
| Whether the Court of Appeals may decline to follow Dull | State: Dull was wrongly decided and should not control this case | Court: Bound to follow Kansas Supreme Court precedent absent indication of departure | Held: Court of Appeals must follow Dull; no basis to overrule it |
Key Cases Cited
- State v. Dull, 302 Kan. 32 (Kan. 2015) (held mandatory lifetime postrelease supervision unconstitutional for juveniles convicted of aggravated indecent liberties with a child and articulated reasoning applicable to juvenile sex offenders generally)
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (two‑step test for categorical Eighth Amendment challenges to juvenile sentences)
- Miller v. Alabama, 567 U.S. 460 (U.S. 2012) (juveniles have diminished culpability; sentencing must account for youth)
- Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (juveniles differ from adults for Eighth Amendment purposes)
- State v. Mossman, 294 Kan. 901 (Kan. 2012) (statutory construction: if a statute can be construed as constitutional, courts should do so)
- State v. Kessler, 276 Kan. 202 (Kan. 2003) (when statutory sentencing procedure is unconstitutional, court lacks authority to impose that part of the sentence)