State v. Martin

Summary

The court affirmed Martin's convictions and concurrent sentences for possessing methamphetamine and possessing a controlled substance without a drug-tax stamp. It held that neither offense was a lesser included offense of the other under the governing Kansas statute and that the Legislature intended multiple punishments despite the overlap in elements. The court also held that the warrantless search of Martin's pill bottle was valid as a search incident to arrest because probable cause for arrest existed before the search, the arrest followed shortly afterward, and the search remained within the permissible scope.