State v. Sims, 280 P.3d 780

Sims filed a pro se motion to correct an illegal sentence challenging five issues across judgments.
Four issues attacked his underlying convictions, not the sentence, and are improper under K.S.A. 22-3504.
The fifth issue alleged the sentencing order was ambiguous as to consecutive versus concurrent terms.
The district court summarily denied the motion for lack of a valid illegal-sentence claim, and this court has jurisdiction over life-sentence motions.
The court reviews de novo whether the record shows entitlement to relief and concludes the fifth claim has no ambiguity; the others address defective complaints and multiplicity outside the scope of 22-3504.
Sims previously challenged his convictions in collateral proceedings; the current motion targets an alleged illegal sentence dated after prior convictions were affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a motion to correct an illegal sentence can attack convictions	Sims should be allowed to raise conviction issues in this motion	Deal limits 22-3504 to illegal-sentence challenges, not convictions	Denied; cannot attack convictions through 22-3504.
Whether the complaint defects render the convictions void	Sims argues multiple essential elements were omitted	Such claims attack the conviction, not the sentence	Denied; improper vehicle for challenging the complaint.
Whether multiplicity/double jeopardy invalidated the two aggravated battery counts	Two batteries from one shooting spree violate double jeopardy	Multiplicity not a jurisdictional defect for 22-3504 relief	Denied; not a basis for relief under 22-3504.
Whether the sentencing order was ambiguous about consecutive vs concurrent terms	The order could be read as ambiguous despite explicit statements	The journal entry and transcript show the sentences run consecutively	Denied; no reasonable interpretation shows ambiguity.
Whether the district court erred by summarily denying without hearing	Summary denial warranted an evidentiary hearing	No hearing required where issues are outside 22-3504 or conclusively resolveable	Denied; summary denial proper.

State v. Deal, 286 Kan. 528 (Kan. 2008) (limits 22-3504 to illegal-sentence corrections; does not reverse convictions)
State v. Nash, 281 Kan. 600 (Kan. 2006) (22-3504 relief limited to illegal sentences)
State v. Hoge, 283 Kan. 219 (Kan. 2007) (summary denial appropriate; not a direct challenge to conviction)
State v. Pennington, 288 Kan. 599 (Kan. 2009) (reaffirmed limitations on 22-3504 procedures)
State v. Conley, 287 Kan. 696 (Kan. 2008) (clarified procedure for 22-3504 summary denial)
State v. Jones, 292 Kan. 910 (Kan. 2011) (de novo review of 22-3504 denials; record accessibility)
State v. Edwards, 281 Kan. 1334 (Kan. 2006) (multiplicity not jurisdictional defect for 22-3504 relief)
State v. Schoonover, 281 Kan. 453 (Kan. 2006) (multiplicity and related sentencing issues)