State v. Rocheleau, 415 P.3d 422

Alfred Rocheleau pleaded guilty in 2013 to aggravated indecent solicitation of a child for conduct occurring 2010–2011.
The 2011 Kansas Legislature amended the Kansas Offender Registration Act (KORA) to change registration for Rocheleau’s offense from 10 years to lifetime, prompting an Ex Post Facto challenge.
Rocheleau timely filed a notice of appeal stating he intended to appeal his "sentence," and the Court of Appeals dismissed his KORA challenge for lack of jurisdiction, treating registration as not part of sentencing.
The Court of Appeals nevertheless addressed the merits and rejected Rocheleau’s Ex Post Facto claim; Rocheleau petitioned for review as to jurisdiction and the Ex Post Facto issue.
The Kansas Supreme Court granted review, held Rocheleau’s notice of appeal sufficient given conflicting precedent at the time, and—on the merits—affirmed that lifetime registration under the 2011 KORA amendment is not punishment for Ex Post Facto purposes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rocheleau’s notice of appeal (stating appeal of "sentence") vested appellate jurisdiction over a KORA challenge	Rocheleau argued the notice should be read broadly given conflicting caselaw and thus was sufficient	State argued KORA registration is not part of the sentence, so the notice limited appeal to sentencing only	Notice was sufficient because conflicting appellate precedent justified a liberal construction; jurisdiction exists to hear KORA challenge
Whether retroactive application of the 2011 KORA amendment (lifetime registration) violates the Ex Post Facto Clause	Rocheleau argued lifetime registration is punitive and thus retroactive application is prohibited	State argued lifetime registration is regulatory, not punitive, so no Ex Post Facto violation	Court held lifetime registration is not punishment for Ex Post Facto purposes and affirmed the registration requirement

State v. Petersen-Beard, 304 Kan. 192 (Kan. 2016) (held KORA lifetime registration is not punishment under the Eighth Amendment and controls Ex Post Facto analysis)
State v. Jackson, 291 Kan. 34 (Kan. 2011) (described offender registration as an incident of sentencing)
Kaelter v. Sokol, 301 Kan. 247 (Kan. 2015) (appellate courts exercise unlimited review over jurisdictional issues)
State v. Boyd, 268 Kan. 600 (Kan. 2000) (notice of appeal requirements should be read broadly when controversy exists)
State v. Ehrlich, 286 Kan. 923 (Kan. 2008) (right to appeal is statutory; appellate jurisdiction depends on compliance with statutory procedure)