State v. Riggs, 123749

Riggs pleaded no contest to possession of methamphetamine; court sentenced him to 24 months with the sentence suspended for 18 months probation.
A probation condition prohibited contact with any person identified by the court or his court services officer, including J.O.
While on probation Riggs accumulated multiple sanctions (including a 120-day jail sanction), continued drug-positive tests, and repeatedly violated the no-contact order.
At a revocation hearing Riggs stipulated he committed a new crime while on probation—aggravated domestic battery against J.O.
The district court found Riggs no longer amenable to probation, revoked probation, and imposed the underlying prison sentence rather than an intermediate (180-day) sanction.
Riggs appealed, arguing the court abused its discretion by imposing the underlying sentence instead of an available intermediate sanction; the court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by imposing the underlying sentence rather than an intermediate sanction	Riggs: Imposition of the underlying sentence was an abuse because a 180‑day sanction remained available	State/District Court: Statute permits bypassing intermediate sanctions when defendant commits a new crime and court reasonably finds defendant not amenable to probation; prior sanctions and violations supported this	Court affirmed: committing a new crime authorized bypassing intermediate sanctions; decision was reasonable and not an abuse of discretion

State v. Coleman, 311 Kan. 332, 460 P.3d 828 (Kan. 2020) (standard of appellate review for probation revocation is abuse of discretion)
State v. Gonzalez-Sandoval, 309 Kan. 113, 431 P.3d 850 (Kan. 2018) (abuse-of-discretion definitions and framework)
State v. Anderson, 291 Kan. 849, 249 P.3d 425 (Kan. 2011) (party alleging abuse of discretion bears the burden)
State v. Dooley, 308 Kan. 641, 423 P.3d 469 (Kan. 2018) (district court must exhaust statutorily prescribed intermediate sanctions unless an enumerated exception applies)