State v. Nambo, 281 P.3d 525

Nambo pled guilty to aggravated robbery for participating with two others in seizing a vehicle and attempting to seize another.
Co-defendants used a firearm; Nambo did not personally possess a firearm during the offenses.
The district court taxed Nambo as an offender under KORA, 22-4902(a)(7).
The Court of Appeals affirmed the registration requirement.
The State conceded Nambo did not physically possess a firearm, but argued registration was still required.
The Supreme Court granted review to decide whether an unarmed accomplice must register under 22-4902(a)(7).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an unarmed accomplice must register under 22-4902(a)(7).	Nambo: statute targets personal firearm use; unarmed accomplices not included.	State: statute punishes use of a deadly weapon in the offense regardless of personal use.	Yes; unarmed accomplices must register under 22-4902(a)(7).

State v. Malmstrom, 291 Kan. 876 (Kan. 2011) (statutory interpretation is a question of law with unlimited review)
Zimmerman v. Board of Wabaunsee County Comm’rs, 289 Kan. 926 (Kan. 2009) (legislative intent governs; plain language controls)
In re W.H., 274 Kan. 813 (Kan. 2002) (interpretation with respect to analogous statutes and savings)
State v. Stuart and Jones, 223 Kan. 600 (Kan. 1978) (statutes penalizing firearm use apply to personal actor)
State v. DeCourcy, 224 Kan. 278 (Kan. 1978) (further development on aiding and abetting and firearm-related penalties)
State v. George, 20 Kan. App. 2d 648 (Kan. App. 1995) (firearm use includes brandishing or using as a weapon)