Justia Kansas Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of distribution of methamphetamine. Defendant appealed, arguing that an audio recording of a nontestifying informant’s statements were improperly admitted into evidence because the informant’s statements were testimonial and thus violated Defendant’s right to confront witnesses under the Sixth Amendment and Crawford v. Washington. The Court of Appeals affirmed, concluding that, under the circumstances, the informant’s statements were not testimonial in nature. The Supreme Court affirmed, holding that the informant’s statements qualified as testimonial, but the error in admitting the informant’s testimonial evidence was harmless. View "State v. Williams" on Justia Law

Defendant was charged with driving under the influence and unlawful exhibition of speed. Defendant moved to suppress the evidence of his driving under the influence, arguing that the officer lacked reasonable suspicion to conduct the traffic stop. The district court denied the motion and convicted Defendant. The court of appeals reversed, concluding (1) Kan. Stat. Ann. 8-1565, which prohibits an unlawful “exhibition of speed or acceleration,” was unconstitutionally vague and indefinite, and the good faith exception was inapplicable; and (2) alternatively, the officer lacked reasonable suspicion to conduct a traffic stop. The Supreme Court (1) affirmed the court of appeals’ decision that the district court erroneously denied the motion to suppress on the grounds that reasonable suspicion did not exist to conduct the traffic stop; (2) summarily vacated the court of appeals’ determination that section 8-1565 is unconstitutionally vague as applied to Defendant; and (3) reversed Defendant’s convictions and vacated his sentences and fines. View "State v. Sharp" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, aggravated kidnapping, and aggravated robbery. The district court imposed a hard fifty sentence for first-degree murder under Kan. Stat. Ann. 21-4635 without fact-finding by the jury. The Supreme Court affirmed Defendant’s convictions but vacated his hard fifty sentence, holding that Defendant was sentenced in violation of the Sixth Amendment because the district court, rather than the jury, found the existence of aggravating factors by a preponderance of the evidence, rather than beyond a reasonable doubt, in violation of Alleyne v. United States. Remanded for resentencing. View "State v. Mattox" on Justia Law

After a jury-waived trial, Defendant was convicted of criminal possession of a firearm by a convicted felon. The court of appeals affirmed. Defendant appealed, raising three arguments. The Supreme Court affirmed, holding (1) with regarding to Defendant’s first and third issues, the court of appeals reached the correct conclusions; and (2) Defendant’s argument that his firearm should have been suppressed as evidence because it was obtained through an illegal search of his car was without merit because the search of Defendant’s car was legal under the exigent circumstances plus probable clause exception to the search warrant requirement. View "State v. Howard" on Justia Law

Defendant was charged with possession of methamphetamine after the vehicle in which he was a passenger was detained for a traffic stop and a law enforcement officer conducted searches of Defendant and his effects, including a cigarette package in which methamphetamine was found. Defendant filed a motion to suppress, arguing that the evidence was obtained during an unlawful warrantless search. The district court denied the motion. The Court of Appeals affirmed, concluding that the final search of the cigarette package was consensual and sufficiently attenuated from an earlier unlawful pat-down of Defendant. The Supreme Court reversed, holding (1) under the totality of the circumstances of this case, the nature of Defendant’s unlawful seizure rendered his consent to the search of the cigarette package involuntary and, therefore, invalid; and (2) therefore, the district court erred in refusing to suppress the evidence seized from the cigarette package. View "State v. Cleverly" on Justia Law

The State sought to have Todd Ellison, a convicted sex offender, involuntarily committed under the Kansas Sexually Violent Predator Act. Under the Act, Ellison was entitled to a jury trial during which the State must prove its case beyond a reasonable doubt. Ellison, however, waited in jail for more than four years without a trial. The district court concluded that the delay violated Ellison’s due process rights, dismissed the action, and ordered Ellison released. A court of appeals panel reversed and remanded the case for further proceedings to more fully address the due process issue. The Supreme Court reversed the court of appeals and affirmed the order of release, holding (1) the district court did not err when it applied Barker v. Wingo to Ellison’s due process claim; and (2) the court of appeals panel erred when it concluded that the district court failed to render adequate factual findings and incorrectly based its release order solely on the length of delay. View "In re Care & Treatment of Ellison" on Justia Law

After a jury trial, Defendant was convicted of identity theft and felony theft. Defendant appealed, arguing, in part, that the district court judge erred in denying Defendant’s motion to suppress evidence obtained from a law enforcement car stop. The court of appeals affirmed, holding that a suspicious character tip such as that motivating the car stop at issue was not enough to support reasonable suspicion of a crime, but reasonable suspicion nonetheless existed. The Supreme Court affirmed, holding that there was no reasonable suspicion of criminal activity to support the stop of the car Defendant was driving, and therefore, Defendant’s motion to suppress should have been granted. View "State v. Chapman" on Justia Law

Defendant was convicted of driving under the influence. Defendant appealed, arguing, among other things, that the district court erred by not granting his motion to suppress evidence of his blood alcohol content obtained from a breath test. Specifically, Defendant alleged that he had been unconstitutionally coerced into submitting to the test because officers threatened to obtain a warrant for a blood test when the officers could have lawfully obtained the warrant. The court of appeals affirmed. The Supreme Court affirmed, holding that Kansas law permits law enforcement officers to to obtain a warrant for a blood draw after a breath test refusal, and therefore, the threat to do so was not coercive. View "City of Dodge City v. Webb" on Justia Law

After a jury trial, Defendant was convicted of capital murder, aggravated burglary, and attempted rape. The district court imposed the death sentence for the capital murder conviction and time in prison for the remaining convictions. The Supreme Court remanded after finding reversible error relating to Defendant’s capital sentence. After a new sentencing proceeding, the district court imposed the death sentence for the capital murder conviction and prison sentences for the remaining convictions. Defendant appealed, raising several allegations of error. The Supreme Court affirmed Defendant’s capital murder conviction and his death sentence but reversed Defendant’s attempted rape conviction as multiplicitous, vacated his sentence for attempted rape, and remanded for resentencing on the other conviction of aggravated burglary, holding that an intervening change in the law required reversal of Defendant’s attempted rape conviction. View "State v. Kleypas" on Justia Law

After a jury trial, Defendant was convicted of premeditated first-degree murder. Defendant appealed, raising several claims of error, including claims of prosecutorial misconduct. The Supreme Court affirmed, holding (1) the State demonstrated beyond a reasonable doubt that a single error on the part of the prosecutor did not affect the outcome of the trial, and Defendant’s remaining prosecutorial misconduct claims were without merit; (2) Defendant did not meet the clear error standard for reversal based on the district judge’s early mistake in making statements to potential jurors before voir dire; (3) the district judge erred in omitting an instruction on reckless second-degree murder, but the jury would not have reached a different verdict had the instruction been given; and (4) cumulative error did not necessitate reversal. View "State v. Carter" on Justia Law