Justia Kansas Supreme Court Opinion Summaries

A prospective employee applied for a position as an occupational therapist with a rehabilitation company, which required COVID-19 vaccination as a condition of employment. The applicant requested a religious exemption, submitting a written statement and a supporting letter from a friend citing religious objections to vaccines developed with fetal cell lines. The company questioned the applicant about her vaccination history and, finding her responses insufficiently sincere, denied the exemption and rescinded the job offer. The applicant filed a complaint with the Kansas Department of Labor, which found the company had violated Kansas law by inquiring into the sincerity of her religious beliefs.The company sought judicial review in the Johnson District Court, which reversed the agency’s decision. The district court held that the relevant Kansas statute, which prohibits employers from inquiring into the sincerity of an employee’s religious beliefs when considering COVID-19 vaccine exemptions, was preempted by federal law—specifically, the federal Vaccine Mandate for Medicare and Medicaid providers and Title VII of the Civil Rights Act. The district court also found the Kansas statute violated due process because it lacked a rational basis.On appeal, the Supreme Court of the State of Kansas reviewed the case de novo. The court held that the federal Vaccine Mandate and Title VII do not expressly or impliedly preempt the Kansas statute, because federal law permits but does not require employers to inquire into religious sincerity. The court further held that the Kansas law does not violate due process, as it is rationally related to the legitimate state interest of protecting religious liberty and provides adequate procedural protections. The Supreme Court of Kansas reversed the district court’s judgment and remanded the case for further proceedings. View "Powerback Rehabilitation v. Dept. of Labor" on Justia Law

Police identified the defendant as a suspect in a violent assault and rape after DNA evidence linked him to the crime. During a custodial interview, the defendant denied involvement and offered an implausible explanation for the DNA match. The victim died three days later, and the State charged the defendant with capital murder and rape. A jury convicted him on both counts, and the district court merged the rape conviction into the capital murder conviction at sentencing.Prior to trial in the Sedgwick District Court, the defendant moved to suppress his statements to police, arguing he could not knowingly and intelligently waive his Miranda rights due to cognitive impairments. The court heard testimony from expert witnesses for both sides and ultimately found the defendant had sufficient cognitive ability to understand his rights and denied the motion to suppress. The defendant also objected to the racial composition of the jury pool, requested an implicit bias instruction, and challenged the court’s refusal to remove a juror for cause. The district court overruled these objections and denied a motion for a new trial.On direct appeal, the Supreme Court of the State of Kansas reviewed the case. The court held that the defendant knowingly and intelligently waived his Miranda rights, finding substantial evidence supported the district court’s conclusion. The court also held that the defendant failed to demonstrate systematic exclusion of a distinctive group from the jury pool or substantial underrepresentation of Black jurors. The court found no error in the district court’s refusal to give an implicit bias instruction, as the requested instruction was not legally appropriate. Finally, the court held that the defendant was not prejudiced by the denial of a for-cause juror challenge because the juror was removed by peremptory strike. The convictions were affirmed. View "State v. McNeal " on Justia Law

Sharmarke Warsame was convicted of two felony counts of identity theft, two misdemeanor counts of theft, and one misdemeanor count of criminal use of a financial card for using stolen credit cards to purchase Target gift cards. The convictions were vacated on direct appeal, and the State dismissed the felony charges after remand. Warsame served 564 days in prison for the vacated and dismissed felony convictions. He then filed a statutory action for wrongful conviction and imprisonment seeking damages, attorney fees, costs, a certificate of innocence, and expungement of all associated convictions.The Johnson District Court denied the State's motion for summary judgment, reasoning that it needed to hear testimony and make findings concerning the alleged facts under which Warsame was convicted. A bench trial followed, and the district court ultimately ruled against Warsame, holding that he had failed to prove his actual innocence by a preponderance of the evidence.Warsame appealed directly to the Kansas Supreme Court, arguing that the district court incorrectly concluded that he committed felony identity theft against the alleged victims as charged and instructed to the jury. The State cross-appealed the denial of summary judgment, arguing that the actual innocence required under the wrongful conviction statute concerns the statutory elements of the charged crime, not the specific facts alleged in the filings or trial.The Kansas Supreme Court agreed with the State, holding that the crime of conviction is defined by statute and is not limited to the specific facts of the charging document. To receive compensation, Warsame was required to prove actual innocence by a preponderance of the evidence under the statutory elements of the charged crime. Warsame failed to meet this burden, as he admitted facts sufficient to prove he intended to defraud some party to receive a benefit. The court affirmed the denial of Warsame's claim. View "In re Wrongful Conviction of Warsame " on Justia Law

In 2015, Brennan R. Trass was charged with first-degree felony murder and criminal possession of a firearm after killing Jose Morales during a drug deal. Trass admitted to the shooting, claiming self-defense. Before trial, the district court appointed multiple attorneys for Trass due to conflicts, causing significant delays. Two weeks before the trial in 2019, the court allowed Trass' attorneys to withdraw due to a conflict and ordered Trass to represent himself with standby counsel. During the trial, Trass was removed from the courtroom for refusing to participate, and his standby counsel took over. The jury convicted Trass.The Reno District Court initially handled the case, where Trass faced multiple attorney changes and delays. Trass filed a direct appeal, and the Kansas Supreme Court remanded the case to the district court to determine the feasibility of a retrospective competency hearing. The district court found Trass competent before and during his 2019 trial. Trass raised several issues on appeal, including violations of his right to counsel, speedy trial rights, and sufficiency of evidence.The Kansas Supreme Court reviewed the case and found that the district court violated Trass' Sixth Amendment right to counsel by forcing him to represent himself without proper advisories or warnings about the dangers of self-representation. The court concluded that Trass did not waive his right to counsel knowingly and intelligently, nor did he forfeit it through egregious misconduct. The violation of Trass' right to counsel constituted structural error, requiring automatic reversal of his convictions. The court also found no violation of Trass' statutory right to a speedy trial and sufficient evidence to support his felony-murder conviction. The case was reversed and remanded for a new trial before a different judge. View "State v. Trass" on Justia Law

The case revolves around William P. Spangler, who was initially convicted of second-degree murder for his role in the shooting death of Faustino Martinez. After serving a prison term longer than his sentence, Spangler was retried and convicted of a lesser charge, involuntary manslaughter. He then sought compensation for the extra time he spent in prison.Spangler's initial conviction was upheld by the Court of Appeals. However, he later filed a motion arguing that he received constitutionally deficient assistance of counsel. The district court agreed, finding that Spangler's trial counsel failed to investigate his mental health status and its effect on his state of mind when he shot Martinez. This failure was deemed prejudicial to Spangler, and a new trial was ordered. The Court of Appeals affirmed this decision.In the retrial, Spangler was again convicted, but this time of involuntary manslaughter rather than second-degree murder. He was released based on time served, having served about four-and-a-half years beyond the sentence imposed for his involuntary manslaughter conviction. Spangler then filed a civil action seeking compensation for the time he spent in prison beyond his involuntary manslaughter sentence.The Supreme Court of the State of Kansas affirmed the district court's decision that Spangler's own conduct caused or brought about his conviction, thus precluding any recovery. The court interpreted the statute to reflect the Legislature's intent to impose a common-sense limitation: Only someone innocent of the criminal conduct supporting the underlying conviction may pursue a claim for damages. Therefore, a claimant like Spangler, who stands convicted of a lesser included offense based on the same charge as a previous conviction, is not eligible to seek relief. View "In re Wrongful Conviction of Spangler" on Justia Law

The Supreme Court of the State of Kansas has upheld the decision of the lower courts in a case involving a plaintiff, Jason Unruh, who alleged that the City of Wichita police officers used excessive force during his arrest. The plaintiff was apprehended after leading police on a car chase and was subsequently subdued while attempting to collect drugs that had spilled onto the ground. Nearly 23 months later, the plaintiff sued for personal injuries, alleging that the officers negligently used excessive force during his arrest. The case focused on whether the plaintiff's claim was for civil battery, which has a one-year statute of limitations, or negligence, which has a longer time limit. The court found that the plaintiff's claim was essentially a battery claim since the officers intentionally used force to make a lawful arrest. The court further clarified that negligence and battery are distinct legal concepts with different elements. The court noted that a negligence claim requires proof of a legally recognized duty that the defendant breached, causing the plaintiff's injuries. The plaintiff failed to establish that the officers owed him a special duty independent of the force used. As such, the plaintiff's claim was time-barred under the one-year statute of limitations for battery. The court affirmed the judgments of the lower courts. View "Unruh v. City of Wichita" on Justia Law

The Supreme Court affirmed the order of the district court reversing its order suppressing evidence found in the car that Defendant was driving on two separate occasions where law enforcement discovered drugs and other contraband, holding that the district court did not abuse its discretion in reversing its suppression order but erred in admitting prior drug use.Defendant was convicted by a jury of two counts of possessing methamphetamine and four counts of possessing drug paraphernalia with intent to use to distribute. The court of appeals reversed and remanded for a new trial on the ground that the district court erroneously allowed the State to introduce evidence relating to Defendant's prior convictions for similar crimes. The Supreme Court affirmed, holding (1) the district court erred in admitting prior drug crime evidence, and the error was not harmless; and (2) the district court did not abuse its discretion in granting the State's motion to reconsider its erroneous suppression ruling. View "State v. Campbell" on Justia Law

The Supreme Court affirmed Defendant's convictions for several crimes after he intentionally set a fire that damaged several apartments, holding, among other things, that the Kansas Legislature has defined the unit of prosecution for aggravated arson as each damaged building or property in which there is a person.Defendant intentionally set fire in the stairwell in front of his daughter's apartment, leading to his conviction, following a jury trial, of six counts of aggravated arson, three counts of attempted first-degree murder, and one count of animal cruelty. On appeal, Defendant argued, among other things, that the district court judge violated his right to be free from double jeopardy by sentencing him on six counts of aggravated arson when the arsonist started only one fire. The Supreme Court disagreed and affirmed, holding (1) Defendant's right to be free from double jeopardy was not violated; (2) the State presented sufficient evidence to support Defendant's convictions for attempted first-degree murder; and (3) the trial judge did not err in denying Defendant's untimely motion for a new trial. View "State v. Buchanan" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court's ruling in this eminent domain case between Tenants and City involving the requirement that a condemning authority provide certain relocation benefits and assistance to those displaced by the government's exercise of eminent domain, holding that the district court lacked subject matter jurisdiction over Tenants' petition to recover relocation expenses.Specifically, the Supreme Court held (1) the district court lacked subject matter jurisdiction over Tenants' petition because the Kansas Eminent Domain Procedure Act (EDPA), Kan. Stat. Ann. 26-501 et seq., neither provides a private right of action to recover relocation benefits nor authorizes judicial review of relocation-benefit determinations in eminent-domain appeals; (2) while the Kansas Relocation Assistance for Persons Displayed by Acquisition of Real Property Act (KRA), Kan. Stat. Ann. 58-3501 et seq., does provide an administrative remedy to vindicate the statutory right to relocation benefits, Tenants' failure to exhaust this administrative remedy deprived the district court of subject matter jurisdiction under the KRA; and (3) while Kan. Stat. Ann. 60-2101(d) authorizes appeals to the district court from certain final judgments and orders of a political subdivision, the statute did not apply in this case. View "Kan. Fire & Safety Equipment v. City of Topeka" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, selling sexual relations, and two counts of felony theft, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant argued that the district court erred in determining that her incriminating statements made to law enforcement confessing to the murder were made voluntarily. Among other things, Defendant contended that sleep deprivation and drug use tainted her interview and that her confinement in the interview room was coercive. The Supreme Court affirmed, holding (1) the district court correctly held that Defendant's statements were freely, voluntarily, and knowingly given and admissible at trial; and (2) ample evidence supported the jury's finding of premeditation. View "State v. Spencer" on Justia Law