State v. Coleman

I agree with the majority’s analysis on the multiplicity issue. Coleman’s possessing the fraudulent check and then transferring it to another *672were not separate crimes for which he could be convicted and punished twice. But I disagree with the majority’s analysis of the alternative means issue and the holding in State v. Foster, 46 Kan. App. 2d 233, 264 P.3d 116 (2011), rev. granted 293 Kan. 1109 (2012), upon which it relies.

I agree with the Foster analysis with respect to the “issuing or delivering” of a negotiable instrument. These are not alternative means by which an instrument is…