Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s conviction for felony murder, holding that sufficient evidence supported the conviction even where the State charged Defendant as the killer but the trial evidence established that his cousin fired the fatal shot.The Court held (1) because the trial record provided sufficient evidence that Defendant participated in the crime of an aggravated burglary during which an individual was killed, and because the issue of whether Defendant was the triggerman bore no relevance to that determination, a rational factfinder could have found Defendant guilty of felony murder beyond a reasonable doubt; (2) the felony-murder elements instruction was not overly broad; and (3) any alleged error in the felony-murder elements instruction was harmless. View "State v. Robinson" on Justia Law

The district court properly suppressed drug-related evidence discovered in a vehicle search following a traffic stop because the officer improperly prolonged the traffic stop.The district court found the initial traffic stop was lawful and that the stop ended when the officer gave Defendant a warning citation and his documents and told him he was free to leave. The court concluded that a consensual encounter then occurred but ended when the officer told Defendant to sit down inside the police car and that there was no probable cause to justify the vehicle search. The Supreme Court affirmed, holding that the officer did not have reasonable suspicion to detain Defendant after the traffic stop, and therefore, the State did not meet its burden to show that the challenged seizure was lawful. View "State v. Lowery" on Justia Law

A law enforcement officer’s detailed questions into a driver’s travel plans measurably extended the stop’s duration and were not justified by any reasonable suspicion of or probable cause to believe there was other criminal activity.Defendant moved to suppress the traffic stop evidence, arguing that the officer measurably extended the stop by asking travel plan questions before processing the driver’s license and warrant information. The court granted the motion to suppress, concluding that the officer measurably extended the stop with travel plan questioning unrelated to the traffic violation and that the officer lacked a reasonable suspicion that other criminal activity was occurring to justify the delay. The court of appeals reversed, holding that no constitutional violation occurred because travel plan questions are always within a stop’s scope. The Supreme Court reversed, holding that because there was no colorable, independent justification for the portions of the detention attributable solely to unrelated inquiries into Defendant’s travel plans, this extended detention violated the Fourth Amendment. View "State v. Jimenez" on Justia Law

The Supreme Court held that the lower courts erred in concluding that the traffic stop in this case was impermissibly extended.The district court suppressed from evidence thirty-eight pounds of marijuana seized after a traffic stop, finding that the stop was unconstitutionally extended. The court of appeals affirmed. The Supreme Court disagreed with the lower courts, holding (1) discrepancies between the driver’s statements and the vehicle-related documents justified the deputy’s progressive questioning; (2) the questioning occurred simultaneously with the deputy’s appropriate steps in processing the traffic stop; and (3) the circumstances provided the officer reasonable suspicion to extend the detention and for a drug dog sniff. View "State v. Schooler" on Justia Law

The Supreme Court rejected the arguments of Plaintiffs, two public school teachers, who sought a judgment declaring the 2014 amendments to the Teacher Due Process Act, Kan. Stat. Ann. 72-5436 et seq., unconstitutional because the legislation constituted a taking of their property without due process.Before July 1, 2014, the contracts of tenured elementary and secondary teachers in Kansas school districts automatically continued into the next school year unless the school district gave a notice of termination or nonrenewal that set out the reasons for the termination or nonrenewal and notified the teacher of his rights to a due process hearing. The 2014 amendments removed both the requirement that the school district’s Board of Education state its reasons for the termination or nonrenewal and the right to a due process hearing. When Plaintiffs were informed that the Board would not be renewing their teaching contracts, they brought this action. The Supreme Court held that Plaintiffs did not have a property interest that was entitled to constitutional protection under either the federal or state constitution. View "Scribner v. Board of Education of U.S.D. No. 492" on Justia Law

The Supreme Court affirmed the decisions of the district court and court of appeals ruling that a search of Defendant’s van, which resulted in the discovery of drugs and a meth pipe, was not in violation of Defendant’s Fourth Amendment rights. Specifically, the Court held that the district court properly denied Defendant’s motion to suppress because assuming, without deciding, that the initial encounter became an investigatory detention, it was supported by reasonable suspicion and was therefore legal, and Defendant’s consent to the search during that time was not tainted. View "State v. Hanke" on Justia Law

The Supreme Court reversed Defendant’s convictions for two counts of premeditated first-degree murder. The Court held (1) sufficient evidence existed such that a rational fact-finder could have found Defendant guilty beyond a reasonable doubt of the two murders; (2) the prosecutor committed misconduct by falsely claiming that one of the victims got a protection from abuse order against Defendant from the district court, and this error prejudiced Defendant’s due process right to a fair trial and required reversal; and (3) the prosecutor committed other errors in arguments to the jury and by disobeying a court order. The Court remanded this case to the district court for further proceedings. View "State v. Chandler" on Justia Law

The Supreme Court affirmed Defendant’s conviction for unintentional second-degree murder for shooting and killing his friend while they celebrated New Year’s Eve. The Court held (1) contrary to Defendant’s assertion, the statute defining unintentional second-degree murder is not unconstitutionally vague; (2) the evidence supported the jury’s finding that Defendant acted under circumstances manifesting extreme indifference to the value of human life; (3) the district court’s procedure when answering a jury question did not violate Defendant’s right to be present at every critical stage of the trial, and the court’s answer to the question was not an abuse of discretion; and (4) the court’s failure to give a limiting instruction about certain evidence was not in error. View "State v. Gonzalez" on Justia Law

The Supreme Court affirmed Defendant’s conviction for unintentional second-degree murder for shooting and killing his friend while they celebrated New Year’s Eve. The Court held (1) contrary to Defendant’s assertion, the statute defining unintentional second-degree murder is not unconstitutionally vague; (2) the evidence supported the jury’s finding that Defendant acted under circumstances manifesting extreme indifference to the value of human life; (3) the district court’s procedure when answering a jury question did not violate Defendant’s right to be present at every critical stage of the trial, and the court’s answer to the question was not an abuse of discretion; and (4) the court’s failure to give a limiting instruction about certain evidence was not in error. View "State v. Gonzalez" on Justia Law

The district court incorrectly sentenced Defendant by misclassifying a 2007 Michigan home invasion conviction as a person felony when calculating Defendant’s criminal history score under the revised Kansas Sentencing Guidelines Act.Defendant was convicted of criminal possession of a firearm and theft. The sentencing court imposed a sentence of eighteen months’ imprisonment. The court of appeals affirmed, holding (1) the prosecutor committed two errors during closing argument, but the errors were harmless; and (2) the district court correctly classified the Michigan conviction as a person felony. The Supreme Court affirmed Defendant’s convictions but vacated his sentence, holding (1) the prosecutorial error in closing argument was harmless; but (2) the Michigan conviction must be scored as a nonperson felony because the Michigan home invasion was not comparable to the Kansas offense of burglary of a dwelling as it existed when Defendant committed the crimes in this case. View "State v. Sturgis" on Justia Law