State v. Robertson, 298 Kan. 342

Joshua James Robertson was convicted in 2002 of first-degree murder, arson, and aggravated burglary and received a hard-50 life sentence based on an especially heinous finding.
The prosecution relied in part on a videotaped interview of Robertson that was played for the jury.
Robertson unsuccessfully appealed his convictions and the denial of suppression on direct appeal and in multiple subsequent postconviction motions (including a K.S.A. 60-1507 petition).
He later obtained a copy of the interview videotape and filed a pro se motion under K.S.A. 22-3504 to correct an illegal sentence and clerical errors, asserting issues tied to the use of his statements.
The district court summarily denied the motion; Robertson appealed, arguing the lack of an evidentiary hearing prevented meaningful review and that res judicata did not bar his claim because he hadn’t raised illegality of sentence on direct appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether summary denial without an evidentiary hearing precludes meaningful appellate review	Robertson: absence of hearing prevents proper review of his claim about the videotaped interview	State: record and written district-court order conclusively show no entitlement to relief; no hearing required	Court: de novo review on the record; district court’s findings were sufficiently memorialized and no evidentiary hearing was needed
Whether res judicata bars Robertson’s renewed suppression/illegal-sentence claim	Robertson: claim about post-invocation questioning (McNeil) should not be barred because he did not raise illegality on direct appeal	State: identical parties, claims, and grounds were previously litigated or could have been raised; final judgments foreclose relitigation	Court: res judicata applies; motion is a repetitive vehicle to relitigate issues already decided; affirmed

State v. Robertson, 279 Kan. 291 (review of suppression and direct appeal)
Trotter v. State, 288 Kan. 112 (definition of illegal sentence)
State v. Edwards, 281 Kan. 1334 (clarifying illegal sentence definitions)
Trotter v. State, 296 Kan. 898 (standard for appellate review of summary denials)
McNeil v. Wisconsin, 501 U.S. 171 (invocation of counsel and questioning consequences)
In re Care & Treatment of Sporn, 289 Kan. 681 (res judicata requirements)
State v. Martin, 294 Kan. 638 (res judicata applied to recurring criminal claims)
State v. Kelly, 291 Kan. 868 (standard of review for res judicata applicability)
State v. Conley, 287 Kan. 696 (rejecting attempts to relitigate prior rulings)