State v. Scheuerman, 502 P.3d 502

On August 8, 2016, officers stopped a vehicle; passenger Robert Scheuerman held a gun to his head, was taken into custody, and stated any "dope" in the car was his.
Because the driver (Finnigan) was detained, officers impounded the vehicle and conducted an inventory search that uncovered a backpack with drugs and paraphernalia.
KBI testing (stipulated by the parties) showed Scheuerman possessed at least 3.5 grams but less than 100 grams of methamphetamine.
The State agreed to amend the charged count to a lesser felony (drug severity level 3: at least 1 gram but less than 3.5 grams) as part of the stipulated bench trial; the district court found Scheuerman guilty.
The Court of Appeals reversed for insufficient evidence, reasoning the stipulation (3.5–100 g) could not support the reduced charge (1–3.5 g), and held Scheuerman lacked standing to challenge the vehicle search; the State sought review.
The Kansas Supreme Court reversed the Court of Appeals on sufficiency, affirmed that Scheuerman lacked Fourth Amendment standing as a passenger, and therefore affirmed the conviction.

Issue	State's Argument	Scheuerman's Argument	Held
Whether a stipulation that defendant possessed at least 3.5 g but <100 g of methamphetamine can support conviction for a reduced charged offense requiring 1 g–<3.5 g	A greater proven quantity necessarily establishes possession of any lesser quantity; amounts and felony levels are cumulative, so the stipulation supports the amended charge	The stipulated quantity (≥3.5 g) falls outside the amended charge's range (≥1 g but <3.5 g), so evidence is insufficient to convict of the lesser offense	Court held amounts are cumulative; proof of a greater amount supports conviction of lesser-quantity statutory tiers — reversal of Court of Appeals on sufficiency; district court conviction affirmed
Whether Scheuerman (a passenger) had Fourth Amendment standing to challenge the vehicle search	State: passenger lacked possessory/right-to-control interest in the vehicle and thus lacked standing	Scheuerman: as a passenger (akin to a social guest) he had a reasonable expectation of privacy and could challenge the search	Court held Scheuerman lacked standing because he showed no ownership, possessory interest, control, or right to exclude; Court of Appeals' holding on standing affirmed

Johnson v. U.S. Food Serv., 312 Kan. 597 (Kansas 2021) (plain-language statutory-construction rule).
State v. Walker, 280 Kan. 513 (Kansas 2005) (statute may be ambiguous in application).
State v. Darrow, 304 Kan. 710 (Kansas 2016) (de novo sufficiency review on stipulated facts).
State v. Gensler, 308 Kan. 674 (Kansas 2018) (possession of "any" controlled substance criminalized).
State v. Toliver, 306 Kan. 146 (Kansas 2017) (avoid absurd statutory interpretations).
Byrd v. United States, 138 S. Ct. 1518 (U.S. 2018) (passenger privacy not categorically foreclosed; focus on lawful possession/control).
California v. Acevedo, 500 U.S. 565 (U.S. 1991) (lesser expectation of privacy in vehicles than homes).
State v. Gilbert, 292 Kan. 428 (Kansas 2011) (passenger may challenge a stop but lacks standing to challenge a search absent possessory interest).