State v. Samuel, 432 P.3d 666

In 1996 Samuel, age 16, killed Patrick Brunner; he pled guilty to second-degree murder (an off-grid person felony) and in 1997 was sentenced to life imprisonment with a mandatory 10-year term before parole eligibility.
In 2016 Samuel filed a K.S.A. 22-3504(1) motion to correct an illegal sentence, arguing Miller v. Alabama and Montgomery v. Louisiana required relief because he was a juvenile when he committed the crime.
Samuel acknowledged Miller addressed mandatory life-without-parole for juveniles but asked the court to extend Miller to his life-with-parole sentence; alternatively he argued the parole-related lifetime supervision was substantively unconstitutional (citing Dull).
The district court summarily denied the motion, holding a K.S.A. 22-3504 motion is not the proper vehicle to raise constitutional challenges to a sentence and alternatively finding the sentence constitutional.
Samuel directly appealed to the Kansas Supreme Court (direct appeal proper because a life sentence for an off-grid homicide was imposed).
The Kansas Supreme Court affirmed, holding K.S.A. 22-3504 does not permit challenging a sentence as unconstitutional and declined to overrule controlling precedent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a motion under K.S.A. 22-3504(1) may be used to raise a federal Eighth Amendment challenge to a sentence	Samuel: Miller/Montgomery require relief for juvenile offender; his life-with-parole sentence (and lifetime supervision) is unconstitutional	State: K.S.A. 22-3504(1) is limited to statutory/clerical illegality claims and cannot be used to raise constitutional challenges	Court: Denied — statutory motion cannot be used to raise constitutional sentence claims; affirmed district court
Whether Miller should be extended to mandatory life-with-parole sentences for juveniles	Samuel: Miller’s reasoning should apply to any life sentence imposed on a juvenile	State: Miller pertains to life-without-parole; existing Kansas precedents do not extend Miller to life-with-parole	Court: Did not extend Miller via 22-3504 motion; declined to disturb precedent
Whether mandatory lifetime postrelease supervision renders the sentence substantively unconstitutional for juveniles	Samuel: Lifetime supervision at parole is categorically unconstitutional for juvenile offenders (invoking Dull)	State: Dull does not control this sentence; sentence is constitutional under Kansas law	Court: Rejected challenge in this procedural posture; did not grant relief

Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life-without-parole for those under 18 violates Eighth Amendment)
State v. Amos, 307 Kan. 147 (2017) (motion to correct illegal sentence under K.S.A. 22-3504 cannot raise constitutional sentencing claims)
State v. Warrior, 303 Kan. 1008 (2016) (K.S.A. 22-3504 does not cover claims that a sentence violates a constitutional provision)
State v. Brown, 300 Kan. 542 (2014) (upholding mandatory life-type sentence imposed on juvenile against Eighth Amendment challenge)
State v. Trotter, 296 Kan. 898 (2013) (defining "illegal sentence" categories under K.S.A. 22-3504)