State v. Rogers, 298 P.3d 325

Rogers pleaded no contest to aggravated criminal sodomy as an off-grid offense for acts on a 7-year-old.
District court sentenced him to life without parole for 25 years and lifetime postrelease supervision.
State dismissed one of two charged counts as part of a plea agreement.
Rogers challenged both the prison term and the postrelease supervision as disproportionate under Freeman and the Kansas Constitution.
District court denied objections and imposed the hard 25-life sentence plus lifetime postrelease supervision.
The court later vacated the postrelease supervision as illegal, leaving the prison term challenged on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are Freeman factors sufficient for review and remand under Seward?	Rogers argues findings are insufficient and Seward requires remand.	State argues findings were adequate; Seward does not require remand here.	Remand not required; record supports constitutional review on appeal.
Is Rogers' hard 25 life sentence constitutional under Freeman?	Freeman factors show disproportionality due to age, lack of harm, and comparison to other crimes.	District court properly weighed offense, offender, and protections of children; not disproportionate.	Sentence constitutional under Freeman factors.
Was the district court's factual finding adequate on the first Freeman factor?	Court relied only on age and offender history, neglecting offender character.	Record shows age, vulnerability of victim, and danger to society; sufficient.	Findings adequate for appellate review.
Is the postrelease supervision component legal?	Lifetime postrelease supervision mirrors parole and is unlawful here.	Not addressed as independent issue; may be valid but reviewed together with sentence.	Postrelease supervision vacated as illegal; issue moot.

State v. Britt, 295 Kan. 1018 (2012) ( Freeman factor review; non-deferential de novo review of legal determinations)
State v. Seward, 289 Kan. 715 (2009) (remand for Freeman findings if necessary; duty to ensure adequate findings)
State v. Woodard, 294 Kan. 717 (2012) (Jessica's Law compared with other crimes; not all-homicide-centered)
State v. Ortega-Cadelan, 287 Kan. 157 (2008) (Freeman factors; first factor inherently factual; others legal)
State v. Easterling, 289 Kan. 470 (2009) (failure to brief all Freeman factors → not effectively decided)
State v. Gomez, 290 Kan. 858 (2010) (Freeman factors applicability to disproportionate sentences)