State v. Echols

── State v. Echols ── Court: Court of Appeals of Kansas Date: June 05, 2026 Category: General NOT DESIGNATED FOR PUBLICATION No. 128,457 IN THE COURT OF APPEALS OF THE STATE OF KANSAS STATE OF KANSAS, Appellee, v. PATRICIA ECHOLS, Appellant. MEMORANDUM OPINION Appeal from Sedgwick District Court; SEAN M.A. HATFIELD, judge. Submitted without oral argument. Opinion filed June 5, 2026. Affirmed. Ryan J. Eddinger, of Kansas Appellate Defender Office, for appellant. Daniel Wells, assistant district attorney, Marc Bennett, district attorney, and Kris W. Kobach, attorney general, for appellee. Before GARDNER, P.J., MALONE and ATCHESON, JJ. PER CURIAM: Patricia Echols appeals her conviction of aggravated assault. Her sole argument on appeal is that the evidence fails to prove that the victim had a reasonable apprehension of immediate bodily harm, as is necessary for aggravated assault. After careful review, we affirm. 1  FACTUAL AND PROCEDURAL BACKGROUND Echols and Deadria Adams knew each other for approximately a decade and lived across the street from each other in Wichita, but, as Echols remarks, the two were not neighborly. On October 21, 2023, Adams walked across the street towards Echols' next door neighbor's house and arrived in the neighbor's driveway. Echols then approached less than five feet from where Adams was standing and "pull[ed] this gun out [of] [a] bag and pointed it dead" at Adams. Trial testimony confirmed that Echols pointed the gun towards Adams' chest or head. As she was drawing the gun, Echols said to Adams, "I told you you can't come visit anybody on this side of the street." Adams responded by yelling to ask her cousin to call the police. Adams said she retreated and took cover behind a vehicle because, "in my mind, if I get behind this car and she's still shooting, she can—I will at least be protected a little bit." After making it around the vehicle, Adams fled to her house, kicking her sandals off so she could run faster. Adams testified, "I was devastated, scared for my life." When she was asked whether she thought that Echols was going to use the gun on her, Adams recalled feeling "like [Echols] was going to use it. Why else would you pull a gun on somebody?" Although she had asked her cousin to call 911, Adams called 911 herself when she reached her house. She also put on a new pair of shoes because Adams "knew [Echols] had kept my shoe in her yard. I wasn't going in there to get it." Adams was "shocked," "scared," "devastated," "blown away," and in a state of disbelief when Echols pulled a gun on her. But she also knew of Echols' reputation and had previously called Echols by her street name—"pistol packing Pat." 2  Tamara Green, Adams' cousin, witnessed the encounter between Echols and Adams. Green testified that she watched Adams cross the street to visit a neighbor and saw Echols come out of her house "waving the gun around." Green heard Echols warn Adams that she was not allowed to visit Echols' side of the street. As soon as Adams saw the gun, the two began exchanging words. Seeing the volatile situation developing, Green called 911. Green's 911 call was played for the jury. Indira Henry lived down the street from Adams and Echols. On the day of the altercation she was sitting on her front porch when she saw Echols warn Adams that she was not supposed to be on Echols' side of the street, but Adams responded to Echols that she could do whatever she wanted to do. Henry recalled seeing Echols with her arms outstretched in Adams' direction and hearing Adams asking