Sentencing Does Not Terminate District Court Jurisdiction Over Motions to Arrest Judgment: Commentary on City of Mission v. VanHorn

I. Introduction

The Kansas Supreme Court’s decision in City of Mission v. VanHorn, No. 127,093 (Kan. Nov. 26, 2025), addresses a recurring and often misunderstood problem in criminal practice: when, exactly, does a district court lose jurisdiction over a criminal case, and how do posttrial motions fit into that framework?

The case arises from municipal ordinance violations—disorderly conduct and criminal trespass—prosecuted by the City of Mission. After a conviction in municipal court and a trial de novo in district court, the defendant, Christopher VanHorn, filed posttrial motions, including a motion for arrest of judgment under K.S.A. 22-3502. His notice of appeal to the Court of Appeals came months after sentencing but within 14 days of the district court’s denial of that motion.

The Court of Appeals dismissed his appeal, concluding it lacked jurisdiction because (1) VanHorn did not file a notice of appeal within 14 days of his conviction and sentence, and (2) the district court itself lacked jurisdiction to entertain a motion for arrest of judgment filed after sentencing, based on language from State v. Tafoya, 304 Kan. 663, 372 P.3d 1247 (2016). The Kansas Supreme Court granted review to examine the Court of Appeals’ jurisdictional rulings.

In a per curiam opinion, the Court clarifies Kansas law on criminal jurisdiction in three critical respects:

A district court retains jurisdiction to decide a timely motion for arrest of judgment under K.S.A. 22-3502 even when the motion is filed after sentencing; the date of sentencing does not cut off that jurisdiction.
An appeal taken within 14 days from the district court’s denial of a posttrial motion for arrest of judgment vests appellate jurisdiction in the Court of Appeals over the issues raised in that motion.
The scope of appellate review is limited to rulings identified in the notice of appeal.

Most significantly, the Court recognizes that its own prior formulation in Tafoya—that a district court loses jurisdiction over a criminal case once sentence is pronounced—was overbroad, and it narrows that rule by returning to the actual holdings and context of earlier cases such as State v. Hall and State v. Guder.

II. Summary of the Opinion

A. Factual and Procedural Background

The case began with an incident at a Salvation Army store in Mission, Kansas. The City charged VanHorn in municipal court with:

One count of disorderly conduct, and
One count of criminal trespass,

both under city ordinances. The municipal judge found him guilty on both counts. VanHorn appealed to the district court, triggering a trial de novo as Kansas law permits for municipal court appeals.

In district court, VanHorn—acting pro se—filed numerous pretrial motions challenging:

Service of process,
The sufficiency of the complaint, and
The district court’s jurisdiction.

After a pretrial hearing, the district court denied these motions, finding jurisdiction proper and rejecting his arguments regarding arraignment and process.

On August 21, 2023, the district court conducted a bench trial de novo. At the conclusion, the court found VanHorn guilty of both offenses and, without objection, sentenced him the same day. The court advised VanHorn he had 14 days to appeal “any adverse ruling.”

The key timing events are:

August 21, 2023: Guilty findings and sentencing in district court.
August 23, 2023 (two days later): VanHorn files a posttrial motion for findings of fact and conclusions of law.
August 31, 2023 (eleven days after sentencing/verdict): VanHorn files a motion for arrest of judgment under K.S.A. 22-3502.
September 11, 2023: District court denies the motion for findings of fact and conclusions of law.
November 7, 2023: District court orally denies the motion for arrest of judgment.
November 13, 2023: Written order denying the motion for arrest of judgment is filed.
November 16, 2023: VanHorn files a notice of appeal.

The notice of appeal expressly identified three sets of rulings:

The denial of pretrial motions,
The denial of the posttrial motion for findings of fact and conclusions of law, and
The denial of the motion for arrest of judgment.

The City moved to dismiss, and the Court of Appeals agreed, holding:

The appeal was untimely as to the conviction and sentence because the notice of appeal was filed nearly three months after sentencing, outside the 14-day appeal period under K.S.A. 22-3608(c); and
Although the notice of appeal was timely as to the denial of the motion for arrest of judgment, the district court lacked jurisdiction to hear that motion after sentencing, relying on State v. Tafoya, so the Court of Appeals itself lacked jurisdiction over that ruling.

The Kansas Supreme Court granted review solely on the Court of Appeals’ jurisdictional determinations and invited supplemental briefing on the interplay of several statutes—K.S.A. 22-3424(c), K.S.A. 22-3502, K.S.A. 22-3608(c)—and Tafoya, as well as the Court of Appeals’ reliance on City of Garden City v. Bird, an unpublished 2006 decision.

B. Holdings

The Court’s holdings, reflected in the syllabus and the body of the opinion, are:

District court jurisdiction over motions to arrest judgment. K.S.A. 22-3502 gives a defendant 14 days after a finding of guilt to file a motion for arrest of judgment. The date of sentencing does not affect the district court’s jurisdiction to hear such a motion. A district court may entertain a timely motion for arrest of judgment even if sentence has already been pronounced.
Appellate jurisdiction over denial of posttrial motions. When a defendant files a notice of appeal within 14 days after a district court’s denial of a posttrial motion for arrest of judgment, the Court of Appeals has appellate jurisdiction over the issues raised in that motion.
Scope of appellate review tied to notice of appeal. Appellate review is limited to rulings specified in the notice of appeal. Because VanHorn confined his notice and petition for review to the denial of his motion for arrest of judgment, issues relating to his conviction and sentence are outside the scope of the Supreme Court’s review in this case.

Applying those principles, the Court:

Holds that the district court had jurisdiction to decide VanHorn’s motion to arrest judgment, despite having already sentenced him;
Holds that the Court of Appeals had jurisdiction over VanHorn’s timely appeal from the denial of that motion; and
Reverses the Court of Appeals’ dismissal and remands the case to that court for further proceedings, limited to VanHorn’s appeal from the denial of the motion for arrest of judgment.

III. Analysis

A. Precedents and Authorities Cited

1. State v. Tafoya and the source of the overbroad jurisdictional rule

The Court of Appeals relied on language from State v. Tafoya, 304 Kan. 663, 667, 372 P.3d 1247 (2016), which stated:

“Once sentence is pronounced and judgment entered, the district court loses jurisdiction over a criminal case except to correct arithmetic or clerical errors.”

From that statement, the Court of Appeals concluded that once the district court sentenced VanHorn, it no longer had jurisdiction to rule on a motion to arrest judgment filed thereafter, except for purely clerical matters.

The Kansas Supreme Court acknowledges that the Court of Appeals was “duty bound” to follow Tafoya under State v. Patton, 315 Kan. 1, 16, 503 P.3d 1022 (2022), which holds that lower courts must follow Supreme Court precedent absent clear indication of departure. But the Court also recognizes that Tafoya overstated the jurisdictional rule.

Critically, Tafoya cited State v. Hall, 298 Kan. 978, 319 P.3d 506 (2014), as support. Hall, however, was not about posttrial motions like a motion for arrest of judgment. Instead, Hall involved:

“Once a legal sentence has been pronounced from the bench, the sentencing court loses subject matter jurisdiction to modify that sentence except to correct arithmetic or clerical errors.” (Emphasis added.)

The Court in VanHorn correctly observes that Hall (and the earlier case State v. Guder, 293 Kan. 763, 267 P.3d 751 [2012], which it cites) concern the narrow question of when a legally imposed sentence may be modified. They do not address broader posttrial jurisdiction over the criminal case itself or over statutorily authorized posttrial motions.

By eliding the limitation “to modify that sentence,” the language in Tafoya effectively expanded a narrow rule about sentence modification into a sweeping rule about the end of district court jurisdiction in criminal cases generally. VanHorn directly corrects that overbreadth.

2. State v. Hall and State v. Guder: limits on sentence modification

Hall, 298 Kan. at 983, and Guder, 293 Kan. at 766, implement K.S.A. 21-4721(i) (now codified at K.S.A. 21-6820(i)), which sharply limit a district court’s ability to alter a sentence after it has been legally imposed. Those cases state that once a lawful sentence has been pronounced, the district court’s jurisdiction to modify that sentence is confined to correcting arithmetic or clerical errors, absent specific statutory authorization.

The VanHorn Court emphasizes that this “loss of jurisdiction” language is about the power to change a lawful sentence, not about general case jurisdiction or posttrial motions authorized by separate statutes. This distinction is central to the opinion’s reasoning and to its clarification of the law.

3. State v. Thomas, State v. Thurber, and State v. Edwards (2024): when jurisdiction transfers to the appellate courts

To restate the correct general rule, the Court looks to more recent precedent:

State v. Thomas, 307 Kan. 733, 749, 415 P.3d 430 (2018): This case states that “once the case is appealed and the appeal is docketed, the district court loses jurisdiction.” In other words, jurisdiction does not leave the district court automatically at sentencing; it transfers when the appeal is formally docketed in the appellate court.
State v. Thurber, 313 Kan. 1002, 492 P.3d 1185 (2021): In the syllabus (¶ 5) and discussion at pages 1007-08, the Court reaffirmed the general Thomas rule, but recognized that the Legislature has created specific statutory exceptions. One such exception is K.S.A. 21-2512, which authorizes district courts to rule on motions for DNA testing “even after an appeal has been docketed.” Thurber illustrates how statutory language can carve out jurisdiction for the district court even after the default transfer point.
State v. Edwards, 318 Kan. 567, 544 P.3d 815 (2024): This decision reaffirms both the general principle from Thomas and the Thurber interpretation that K.S.A. 21-2512 creates a legislative exception allowing district court action after docketing. It demonstrates the Court’s willingness to treat statutory authorization as controlling on jurisdictional timing.

VanHorn uses these cases to frame jurisdiction around two points:

The default rule: Jurisdiction transfers to the appellate court when the appeal is docketed there, not at sentencing.
Statutory exceptions: The Legislature may explicitly allow (or require) district courts to retain jurisdiction over particular kinds of motions for particular periods, sometimes even beyond docketing.

The motion for arrest of judgment statute, K.S.A. 22-3502, is treated as such a legislative scheme that must be harmonized with the general jurisdictional rules.

4. Statutory framework: K.S.A. 22-3424(c), 22-3502, and 22-3608(c)

The Court’s analysis rests heavily on three criminal procedure statutes:

K.S.A. 22-3424(c) (judgment and sentence after guilty verdict): After a verdict of guilty, the statute directs that “judgment shall be rendered and sentence pronounced without unreasonable delay, allowing adequate time for the filing and disposition of post-trial motions.” This language expressly contemplates posttrial motions in the period between verdict and finality, and makes clear that scheduling of sentencing must accommodate that.
K.S.A. 22-3502 (motion for arrest of judgment): This provision allows a defendant to move for arrest of judgment “within 14 days after the verdict or finding of guilty, or after a plea of guilty or nolo contendere, or within such further time as the court may fix during the 14-day period.” A motion to arrest judgment typically challenges the legal sufficiency of the charging document or the court’s jurisdiction. Critically, the statute measures the 14-day period from the verdict (or plea), not from sentencing, and does not forbid filing after sentencing.
K.S.A. 22-3608(c) (criminal appeal deadline): This statute provides that a defendant generally has 14 days from the entry of “judgment” to file a notice of appeal. Under Kansas law, the “final judgment” in a criminal case is the sentence, as held in State v. Van Winkle, 256 Kan. 890, 895, 889 P.2d 749 (1995). A timely notice of appeal under 22-3608(c) is typically jurisdictional; if untimely, the appellate court lacks jurisdiction.

These statutes must be read together. K.S.A. 22-3424(c) requires time for posttrial motions; K.S.A. 22-3502 specifies that one such motion may be filed within 14 days after a finding of guilt; and K.S.A. 22-3608(c) imposes a 14-day deadline to appeal from the final judgment (sentence), subject to the effect of posttrial motions.

5. Other cited authorities

The Court also cites several additional cases to support peripheral but important points:

State v. Barnes, 320 Kan. 147, 155, 563 P.3d 1255 (2025): For the proposition that questions of jurisdiction and statutory interpretation receive unlimited (de novo) review.
State v. Gleason, 315 Kan. 222, 226, 505 P.3d 753 (2022), and Materi v. Spurrier, 192 Kan. 291, 292, 387 P.2d 221 (1963): To reaffirm that Kansas courts derive jurisdiction from the Kansas Constitution and statutes.
State v. Van Winkle, 256 Kan. 890, 895, 889 P.2d 749 (1995): To define “final judgment” in a criminal case as the sentence.
State v. Gill, 287 Kan. 289, 294, 196 P.3d 369 (2008): To reinforce that the 14-day appeal period in K.S.A. 22-3608(c) is jurisdictional.
Anderson v. Scheffler, 242 Kan. 857, 861, 752 P.2d 667 (1988): For the principle that appellate review is limited to rulings specified in the notice of appeal.
Mundy v. State, 307 Kan. 280, 291, 408 P.3d 965 (2018): Clarifying that while the appellate court’s jurisdiction is limited to rulings in the notice of appeal, an appellant need only identify the judgment appealed from, not each specific alleged error within that judgment.
State v. Edwards, 260 Kan. 95, 98, 917 P.2d 1322 (1996): To support the idea that a defendant’s withdrawal or failure to pursue an issue on appeal is treated as abandonment of that claim.
State v. Patton, 315 Kan. 1, 16, 503 P.3d 1022 (2022): Emphasizing that the Court of Appeals must follow Kansas Supreme Court precedent.

The opinion also notes K.S.A. 60-2101(b), which gives the Kansas Supreme Court authority to review and correct errors of the Court of Appeals, including jurisdictional errors. However, the Court explains that its review in this case is still constrained by the issues raised in the petition for review and the notice of appeal.

B. The Court’s Legal Reasoning

1. Correcting the overbroad reading of Tafoya

The Court begins by addressing the second rationale the Court of Appeals used to dismiss the case: that the district court lost jurisdiction immediately after sentencing, relying on Tafoya. The Court explains:

Tafoya’s language suggested that sentencing ends district court jurisdiction “over a criminal case,” with only a narrow exception for arithmetic or clerical errors.
But the case cited for that language—Hall—spoke only of jurisdiction to modify a lawful sentence, not to handle posttrial motions that are statutorily authorized.

The Court thus explicitly characterizes Tafoya as overstating “our true jurisdictional rule” and reaffirms that:

“Our recent decisions clarify that a district court generally retains jurisdiction over a criminal case—including posttrial motions—until the appeal is docketed in the appellate court.”

This is a critical doctrinal adjustment. It prevents a misreading of Tafoya from eliminating district court authority over posttrial motions simply because sentencing has occurred.

2. Re-centering jurisdiction on statutes and the docketing rule

Returning to first principles, the Court reiterates that jurisdiction in Kansas courts is a function of:

The Kansas Constitution, and
Statutes enacted by the Legislature.

That includes:

The general rule that district court jurisdiction continues in a criminal case until the appeal is docketed in the appellate court (Thomas, Thurber, Edwards), and
Specific statutory provisions such as K.S.A. 22-3502 that authorize certain actions by the district court after verdict and even after sentencing.

The Court then harmonizes the statutes:

K.S.A. 22-3424(c) requires that sentencing occur “without unreasonable delay” but also that there be “adequate time for the filing and disposition of post-trial motions.”
K.S.A. 22-3502 expressly gives defendants 14 days after a finding of guilt to file a motion for arrest of judgment.
K.S.A. 22-3608(c) establishes a 14-day window to appeal from the final judgment (the sentence), and a timely notice of appeal is generally jurisdictional.

Reading these together, the Court reasons that:

The Legislature clearly contemplated that posttrial motions would exist alongside the sentencing process.
K.S.A. 22-3502’s 14-day window allows a motion to arrest judgment to be filed even after sentence is pronounced, so long as it is within 14 days of the verdict or plea.
This statutory scheme implicitly authorizes district courts to exercise jurisdiction over such motions, even though sentencing has already occurred.

In other words, sentencing does not terminate district court jurisdiction over statutorily authorized posttrial motions filed within the deadlines the Legislature has set.

3. Application to VanHorn’s motion for arrest of judgment

Applying that statutory reading to the facts:

VanHorn’s verdict and sentence were entered on August 21, 2023.
He filed his motion for arrest of judgment on the 11th day thereafter, well within the 14-day period authorized by K.S.A. 22-3502.

Because:

K.S.A. 22-3502 allows a motion to arrest judgment within 14 days after the verdict or finding of guilt, and
The general jurisdictional rule is that the district court retains jurisdiction until the appeal is docketed,

the district court had jurisdiction to hear and decide that motion despite having already sentenced VanHorn. The subsequent denial of the motion on November 13, 2023, was therefore a valid exercise of jurisdiction.

The Court explicitly states its conclusion:

“Based on the applicable statutes and prior caselaw interpreting them, we conclude the district court had jurisdiction to consider VanHorn’s timely motion for arrest of judgment, even though he had already been sentenced.”

This directly rejects the Court of Appeals’ reliance on Tafoya and clarifies that Tafoya’s sweeping formulation is “overbroad” and should not mislead future appellate courts.

4. Appellate jurisdiction over the denial of a motion for arrest of judgment

Having established that the district court had jurisdiction to deny the motion for arrest of judgment, the Court next considers whether the Court of Appeals had jurisdiction over the appeal from that denial.

The critical timing here is:

November 13, 2023: Written order denying the motion is filed.
November 16, 2023: Notice of appeal is filed—three days later.

Under K.S.A. 22-3608(c), a defendant has 14 days to appeal from “the judgment.” In ordinary practice, when a timely posttrial motion is filed and then denied, the appeal deadline runs from that denial for the matters encompassed by the motion. The opinion does not dwell on the tolling mechanics, but it accepts as uncontroversial that the notice of appeal was timely as to the November 13 order.

Thus, the Court holds:

“When a defendant appeals within 14 days from a district court’s denial of a posttrial motion for arrest of judgment, an appellate court obtains appellate jurisdiction over the issues raised in that motion.”

Because:

The district court validly exercised jurisdiction in denying the motion, and
The notice of appeal was filed within 14 days after that denial,

the Court of Appeals had appellate jurisdiction over the issues set forth in the motion to arrest judgment. Its dismissal for lack of jurisdiction was therefore erroneous.

5. Limiting the scope of appellate review to the notice of appeal

The Court then turns to the Court of Appeals’ first rationale for dismissal: that it lacked appellate jurisdiction over issues relating to the conviction and sentence because VanHorn did not file a notice of appeal within 14 days of those rulings. The Kansas Supreme Court acknowledges that it has authority under K.S.A. 60-2101(b) to correct jurisdictional errors by the Court of Appeals, but concludes that this issue is not actually before it.

The reason lies in the interplay of:

Anderson v. Scheffler: Appellate review is limited to rulings specified in the notice of appeal.
Mundy v. State: The appellant must identify the judgment appealed from; they need not list every claimed error, but the jurisdictional focus is still on what judgments are designated.
Edwards (1996): A defendant’s decision to withdraw or not pursue an issue on appeal is treated as abandonment.

Here:

VanHorn’s notice of appeal and subsequent filings focused on the denial of his motion for arrest of judgment and related rulings.
His petition for review expressly challenged the Court of Appeals’ jurisdictional ruling regarding the motion for arrest of judgment and consistently framed the appeal as concerning only that denial.

The Court therefore holds that it “need not address” the Court of Appeals’ determination about the timeliness of any appeal from the conviction and sentence. To do more would exceed the scope set by the notice of appeal and the petition for review. The Supreme Court limits its holding to the issues encompassed within the timely appeal from the denial of the motion to arrest judgment.

Consequently, the Court:

Reverses the Court of Appeals’ dismissal of the appeal, and
Remands the case to the Court of Appeals with directions to consider the appeal solely as to the denial of the motion for arrest of judgment.

C. Impact of the Decision

1. Clarifying district court jurisdiction post-sentencing

The most significant doctrinal impact of City of Mission v. VanHorn is the clear statement that sentencing does not extinguish a district court’s jurisdiction over a criminal case in toto. Instead:

The district court retains jurisdiction over the case, including posttrial motions, until an appeal is docketed in the appellate court, subject to statutory exceptions.
The “loss of jurisdiction” doctrine from Hall, Guder, and Tafoya is limited to the district court’s ability to modify a lawful sentence in the absence of statutory authority.

This will have important practical effects:

District courts cannot refuse to hear a timely motion for arrest of judgment simply because sentencing has already occurred.
Attorneys and defendants can confidently file such motions within 14 days of the verdict without worrying that sentencing has stripped the court of jurisdiction to hear them.
Other posttrial motions with statutory deadlines keyed to the verdict or plea (such as motions for new trial under K.S.A. 22-3501) are likely governed by similar reasoning: the mere fact of sentencing does not negate the court’s statutory power to adjudicate them, as long as they are timely.

2. Strengthening the role of statutory text in jurisdictional analysis

The opinion reinforces a statutory-interpretive approach to jurisdiction. Rather than relying on generalized judicial statements about when jurisdiction ends, courts must:

Identify the specific statutes that confer or limit jurisdiction, and
Read them together with the general rules on when appellate jurisdiction is invoked.

This approach harmonizes:

The general “docketing” rule of Thomas, and
Case-specific statutory directives like K.S.A. 22-3502 (motions to arrest judgment) and K.S.A. 21-2512 (DNA testing motions, as discussed in Thurber and Edwards).

Future jurisdictional disputes—particularly about posttrial motions—are likely to be resolved by careful reference to statutory text, rather than broad, unqualified statements in prior caselaw.

3. Appellate practice: notices of appeal and scope of review

VanHorn also serves as a clear reminder about appellate practice:

Appellate jurisdiction is bounded by the judgments and rulings identified in the notice of appeal.
Even when higher courts have authority to correct jurisdictional errors (as under K.S.A. 60-2101(b)), they will not ordinarily reach issues beyond those specifically raised and preserved.
Abandonment of issues (by not pursuing them in briefs or petitions) will be respected, limiting the scope of appellate decisions.

Practitioners should carefully draft notices of appeal to identify all judgments or orders they intend to challenge and should align their appellate briefing with that scope. In municipal appeals like this one, where multiple stages (municipal court, district court, posttrial motions) occur, precise designation of the target rulings is crucial.

4. Consequences for municipal and ordinance prosecutions

Although the underlying case involved municipal ordinance violations, the jurisdictional principles announced are general to Kansas criminal procedure. They will govern:

Appeals from municipal court convictions to district court, and
Subsequent appeals from district court to the Court of Appeals and the Supreme Court.

In such cases, defendants frequently proceed without counsel, as VanHorn did. The Court’s insistence that a defendant retains the statutory right to file a motion to arrest judgment after sentencing—and that appellate review lies from a denial of that motion—provides a critical safeguard for pro se defendants challenging jurisdiction or the sufficiency of charging documents.

At the same time, the Court’s insistence on adherence to notice-of-appeal limitations underscores that even pro se litigants must clearly articulate which rulings they are appealing.

D. Complex Concepts Simplified

1. What is a motion for arrest of judgment?

A “motion for arrest of judgment” is a posttrial motion that asks the court to refrain from entering or enforcing judgment because of a fundamental defect. Under K.S.A. 22-3502, such a motion can be filed:

Within 14 days after a verdict or finding of guilt, or
Within 14 days after a plea of guilty or nolo contendere.

Typical grounds for arrest of judgment include:

That the complaint, information, or indictment fails to state a crime; or
That the court lacked jurisdiction over the offense or defendant.

If a motion for arrest of judgment is granted, the judgment is “arrested”—meaning the conviction cannot stand on that defective charging instrument or in that court. The prosecution may or may not be able to refile, depending on the defect and procedural posture.

2. “Final judgment,” “verdict,” and “sentence”

These terms are often confused:

Verdict or finding of guilt: The determination that the defendant committed the crime, made by the jury (in a jury trial) or the judge (in a bench trial).
Sentence: The punishment pronounced by the court (e.g., jail time, probation, fines). Under Kansas law, the sentence is the “final judgment” in a criminal case.
Final judgment: For appeal purposes, this is typically the sentence. The clock for filing a notice of appeal under K.S.A. 22-3608(c) usually starts when the sentence is formally entered.

A motion for arrest of judgment is keyed to the verdict or finding of guilt, not to the sentence. But appeal deadlines are keyed to the judgment (sentence), subject to the effects of timely posttrial motions.

3. What does it mean that jurisdiction transfers when an appeal is docketed?

“Docketing” an appeal is the formal step by which an appellate court opens a case and assumes control over it. Before docketing:

The district court retains jurisdiction over the case, including authority to rule on posttrial motions within statutory limits.

Once the appeal is docketed:

The appellate court takes over jurisdiction of the matters on appeal, and
The district court generally loses jurisdiction, except for narrow exceptions (such as clerical corrections or specific statutory authorizations like K.S.A. 21-2512 for DNA motions).

VanHorn reinforces that this “docketing” event—not sentencing—is the ordinary line at which the district court’s authority to act in the case ends.

4. Jurisdiction to modify a sentence vs. jurisdiction over the case

The opinion distinguishes two ideas that are often conflated:

Jurisdiction to modify a lawful sentence: Once a lawful sentence is imposed, the district court’s power to change it is tightly limited; absent statutory authorization, the court can only correct arithmetic or clerical errors (Hall, Guder).
Jurisdiction over the criminal case and posttrial motions: Even after sentencing, the district court may still have authority to act on certain motions, especially where statutes like K.S.A. 22-3502 explicitly allow post-verdict, post-sentence motions within a specified timeframe.

Tafoya blurred this distinction. VanHorn restores it.

5. Why are notices of appeal so important?

A notice of appeal does two critical things:

It invokes the jurisdiction of the appellate court.
It defines which judgment(s) or orders are being appealed.

Appellate courts will:

Refuse to consider rulings not encompassed by the notice of appeal, and
Treat issues not pursued in briefs or petitions as abandoned.

In VanHorn, although it was possible that the Court of Appeals erred about its jurisdiction over VanHorn’s underlying conviction and sentence, the Supreme Court declined to reach that issue because it lay beyond what VanHorn actually appealed and preserved. This demonstrates how crucial it is to properly frame the scope of an appeal at the outset.

IV. Conclusion

City of Mission v. VanHorn is a significant clarification of Kansas criminal procedure in three key respects:

District court jurisdiction over motions to arrest judgment. K.S.A. 22-3502 gives defendants 14 days after a finding of guilt to file a motion for arrest of judgment, and a district court retains jurisdiction to rule on such a motion even if it is filed after sentencing, so long as it is timely.
Appellate jurisdiction over posttrial rulings. When a defendant appeals within 14 days from the denial of a motion for arrest of judgment, the Court of Appeals has jurisdiction over the issues raised in that motion. A contrary rule based on the idea that sentencing automatically ends district court jurisdiction is rejected as a misreading of Tafoya.
Scope of appellate review. Appellate review remains limited to the rulings specified in the notice of appeal and preserved in the petition for review. Even when the Supreme Court can correct jurisdictional errors by the Court of Appeals, it will respect these limits.

By narrowing the overbroad statement in Tafoya, reaffirming the general rule that jurisdiction shifts upon docketing (not sentencing), and elevating statutory text as the primary guide to jurisdictional questions, the Court provides needed clarity to Kansas practitioners and courts. The decision protects defendants’ ability to use statutorily authorized posttrial motions to challenge jurisdictional defects and charging errors, while also underscoring the procedural discipline required in framing appeals.

Going forward, VanHorn will stand as the leading Kansas precedent confirming that sentencing does not terminate a district court’s jurisdiction over timely motions to arrest judgment and that appeals from the denial of such motions, filed within 14 days, are properly within the jurisdiction of the Kansas Court of Appeals.