Abstract
Untied from any mooring, alternative means jurisprudence in Kansas has drifted into a strange and confusing world where “secondary matters” infest every corner of the criminal code. Who knew the Kansas legislature intended to create a class system for criminal elements in this state? A breakdown in the application of Kansas’s ordinary canons of statutory and constitutional construction is to blame. 1 This breakdown has led the state into a morass of artificial and unnecessary distinctions impossible to otherwise conceive. Any discussion about the breakdown now begins with what was meant as a clarifying point in Kansas law with the holding of State v. Wright. 2
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