Justia Kansas Supreme Court Opinion Summaries

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The Supreme Court affirmed the judgment of the district court denying GFTLenexa, LLC relief in an action based on contractual relationships but brought as an inverse condemnation proceeding, holding that there was no error in the reasoning or conclusions of the district court. GFTLenexa, LLC alleged in this action that a condemnation through an eminent domain action resulted in GFTLenexa's intangible property rights being damaged. The action was predicated on its reduced rental income because of an action that it lost to its sublessee involving the condemnation. The district court denied summary judgment to GFTLenexa. The Supreme Court affirmed, holding the proper venue for GFTLenexa to assert its rights was in the eminent domain proceeding, even if it could not have successfully asserted them there because it surrendered its rights through its contractual obligations. View "GFTLenexa, LLC v. City of Lenexa" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, holding that, even if the Court find one error and assume the existence of another, these errors did not, individually or collectively, require reversal of Defendant's conviction. Specifically, the Court held (1) the prosecutor use of the phrase "I think" qualified as error, but this brief indiscretion did not merit reversal; (2) even if the district court erred in failing to instruct sua sponte on reckless second-degree murder and reckless involuntary manslaughter, the error was not clear; (3) Defendant's remaining allegations of error were without merit; and (4) the errors - one identified and one assumed - did not cumulatively prejudice Defendant and did not deprive him of a fair trial. View "State v. Pruitt" on Justia Law

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The Supreme Court affirmed the judgment of the district court sentencing Defendant to lifetime postrelease supervision after he was convicted of burglary, theft, criminal damage to property, aggravated indecent liberties with a child, and criminal sodomy, holding that due to the nature and timing of his offenses, Defendant was subject to lifetime postrelease supervision under Kan. Stat. Ann. 22-371(d)(1)(G). While Defendant's appeal was pending, the Supreme Court released State v. Brook, 440 P.3d 570 (Kan. 2019), ruling that section 22-3717 provided that persons who, like Defendant, committed sexually violent offenses after July 1, 2006 were subject to lifetime postrelease. The Supreme Court affirmed, holding that the date of the sexually violent offense was the controlling factor, with section 22-3717(d)(1)(G) applying to persons who, like Defendant, committed sexually violent crimes on or after July 1, 2006. View "State v. Carpenter" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to withdraw his 1982 guilty pleas following an evidentiary hearing on the motion, holding that Defendant failed to establish a factual basis for his argument and, consequently failed to establish excusable neglect. Specifically, the Court held that Defendant did not meet his burden of establishing any facts that might conceivably support an equitable tolling of the statute of limitations, and therefore, the district court did not abuse its discretion in finding that Defendant did not establish excusable neglect to permit his untimely filing. View "State v. Fox" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the Court of Appeals affirming the judgment of the district court convicting Defendant of reckless driving and second-degree murder for unintentional but reckless homicide, holding that no error infected the district court's rulings on the three issues that Defendant raised in his petition for review. Specifically, the Court held (1) a prior diversion agreement Defendant entered into subsequent to an arrest for driving while intoxicated was properly introduced into evidence in order to prove recklessness; (2) the district court did not abuse its discretion in admitting expert testimony about the relative speeds of the two vehicles at the time of the collision; and (3) the district court did not err in refusing Defendant's requested voluntary intoxication instruction. View "State v. Claerhout" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the district court judge denying Defendant's motion to correct an illegal sentence, holding that where Defendant failed to establish that his sentence was illegal at the time it was imposed the district court correctly denied Defendant's motion to correct an illegal sentence. Defendant was convicted of first-degree murder and aggravated robbery. Based on Defendant's criminal history score, the district judge sentenced him to life in prison for murder and a consecutive 233 months for aggravated robbery. Defendant later filed his motion to correct an illegal sentence, arguing that subsequent changes in the law rendered his sentence illegal. The district court denied the motion. Defendant appealed, arguing that his sentence was illegal under State v. Wetrich, 412 P.3d 984 (Kan. 2018). The Supreme Court affirmed, holding (1) the illegal sentence statute and recent decisions from the Court foreclosed Defendant's challenge to his sentence; and (2) Defendant cannot use a motion to correct an illegal sentence to argue that his sentence is unconstitutional. View "State v. Bryant" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the holdings of the court of appeals reversing Defendant's convictions for, inter alia, criminal possession of a firearm, holding that the court of appeals erred in ruling that the trial judge's admitted sleeping during trial was misconduct but did not rise to the level of structural error and that the district court did not have to obtain a limited jury trial waiver before accepting Defendant's stipulation to an element of the possession charge. Defendant was convicted of criminal possession of a firearm, aggravated assault, and felony criminal discharge of a firearm. The court of appeals reversed the convictions and remanded for a new trial, holding that the trial judge had committed structural error. The Supreme Court reversed, holding (1) the trial judge's "nodding off" during the first day of the trial did not result in the judge so abdicating and abandoning his judicial responsibilities that he was effectively absent from the courtroom, and therefore, there was no structural error; and (2) the district court erred when it accepted Defendant's elemental stipulation without first obtaining a knowing and voluntary jury trial waiver on the record. View "State v. Johnson" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the decision of the court of appeals remanding this case with instructions to enter judgment as a matter of law in favor of the Trust Company of Kansas (TCK) and reverse the jury's verdict finding TCK liable for negligent training, holding that the trial court's jury instructions were erroneous and that, therefore, the case must be remanded for a new trial on proper instructions. Marilyn Parsons sued TCK and its employee, Jon King, asserting various theories of liability. After a trial, the jury found JCK liable for negligent training and King liable for breach of fiduciary duty. The court of appeals reversed as to TCK, finding the evidence insufficient. The Supreme Court reversed, holding (1) the district court's instructions failed to present the jury with an accurate statement of negligence law and improperly separated Parsons' negligence claim against TCK into two causes of action; and (2) the legal errors affected the verdict. View "Reardon v. King" on Justia Law

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In this fee dispute between a hospital that provided medical services to an injured worker and a workers compensation carrier that paid the hospital less than the billed amount for those services the Supreme Court reversed the opinion of the court of appeals reversing the decision of the Workers Compensation Appeals Board upholding a hearing officer's ruling in favor of the carrier, holding that the relief sought by the hospital and ordered by the court of appeals could not be granted in this proceeding. In ruling in favor of the carrier, the hearing officer held that the carrier had appropriately paid the amount required by the schedule for maximum medical fees established by the director of the Division of Workers Compensation. The Board affirmed. The court of appeals reversed, concluding that the Board's enforcement of the maximum medical fee schedule was arbitrary, capricious, and unreasonable because the applicable fee limiting provision had been accidentally created. The Supreme Court reversed, holding (1) the issue of the rulemaking by the director, and the results of any accidental rulemaking, were not properly before the Board; and (2) the Board's refusal to expand the parameters of the fee dispute statute was not unreasonable, arbitrary or capricious. View "Via Christi Hospitals Wichita, Inc. v. Kan-Pak, LLC" on Justia Law

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The Supreme Court affirmed the judgment of the district court rejecting Appellant's argument that a nineteen-month delay between his arrest and trial violated his constitutional right to a speedy trial, holding that Appellant failed to establish a violation of his constitutional right to a speedy trial as guaranteed by the Sixth Amendment to the United States Constitution and section 10 of the Kansas Constitution Bill of Rights. In support of his argument, Appellant contended that the court of appeals erred in ruling that the six months he spent in juvenile detention should not be counted in determining the length of the delay. The Supreme Court affirmed, holding (1) the right to a speedy trial applies in juvenile offender proceedings, and therefore, Appellant's period of juvenile detention should be included in a calculation of how long it took to get to trial; but (2) Appellant's constitutional right to a speedy trial was not violated, even considering the full nineteen-month delay rather than the thirteen months considered by the court of appeals. View "State v. Owens" on Justia Law