The COA held that a prior juvenile adjudication does not count as a "conviction" for offender registration purposes under KORA. The court stated:
The Kansas Offender Registration Act, K.S.A. 22-4901 et seq., requires that sex offenders register for 10 years on a first conviction and for life on a second or subsequent conviction. Because the legislature knows the distinction between juvenile adjudications and adult convictions and has set up a separate registration protocol for juvenile offenders, a juvenile adjudication does not qualify as a conviction for purposes of K.S.A. 22-4906(a).
The COA also reversed Mr. Reese's sentence, noting that the KSC had recently held in State v. Boyer that a prior juvenile adjudication cannot be used to sentence a defendant as a "persistent sex offender."
[Update: the state did not file a PR and the mandate issued on September 15, 2009.]