State v. Waldrup, 263 P.3d 867

Waldrup was convicted of two counts of sale of cocaine, third offense, based on two July 2007 purchases through an undercover operation.
A cooperating witness (Roubison) and a state officer (Thomas) testified to both drug buys and the related recordings.
Waldrup argued multiple issues, including alternative means, speedy-trial rights under the Agreement on Detainers, and various trial-error claims.
Waldrup was arrested in 2007, extradited from Missouri in 2009, and tried in 2009 after a mistrial in 2009; he was sentenced to 162 months.
The district court admitted a broad definitional instruction for sale under the UCSA, and Waldrup challenged related unanimity and informant-corroboration issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is sale of cocaine an alternative means crime due to definitional instruction?	Waldrup argues the definitional instruction created alternative means.	State contends no alternative-means issue since instruction is explanatory, not a separate means.	No; definitional instruction did not create alternative means; evidence supported guilt.
Speedy trial under Agreement on Detainers Article III	Waldrup asserts Article III timelines were violated.	State argues delays were within permitted continuances.	No violation; four continuances were for good cause, extending the 180-day period.
Speedy trial under the Constitution	Waldrup claims constitutional speedy-trial violation.	State relies on Agreement compliance and Barker factors.	No constitutional violation after balancing Barker factors and Agreement timing.
Jury instruction on confidential informant testimony	Waldrup sought a cautionary informant instruction.	State argues evidence corroborated informant, instruction unnecessary.	No error; testimony corroborated and overall instructions protected credibility.
Unanimity instruction on multiple acts	Waldrup contends need for unanimity due to offers and sales.	State contends activities were a continuing course of conduct, not multiple acts.	Not a multiple-acts case; no unanimity instruction required.

State v. Wright, 290 Kan. 194 (2010) (addresses alternative means in Kansas)
State v. Aguirre, 45 Kan. App. 2d 141 (2011) (first-impression on definitional instructions creating alternative means)
State v. Smith, 159 Wash.2d 778 (2007) (informant-definitional instruction not 'means within a means')
State v. White, 234 Kan. 340 (1983) (detainer speedy-trial timing under Article III)
Barker v. Wingo, 407 U.S. 514 (1972) (speedy-trial balancing factors)
State v. Vaughn, 254 Kan. 191 (1993) (constitutional speedy trial despite detainer noncompliance; detainer act not exclusive)
Townsend v. State, 215 Kan. 485 (1974) (detainer act governs inmate speedy-trial rights; compliance matters)
State v. Osby, 246 Kan. 621 (1990) (informant evidence admissibility in credibility context)
State v. Griffin, 221 Kan. 83 (1976) (use of prior statutory definitions in defining sale)
State v. Dolack, 216 Kan. 622 (1975) (legislature may define speedy-trial rights; detainer act context)