Justia Kansas Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of attempted first-degree murder. The court of appeals affirmed. Both the State and Defendant appealed. The Supreme Court affirmed Defendant conviction but vacated his sentence, holding (1) Defendant’s Sixth Amendment right to a public trial did not attach to the questioning of the victim, and therefore, the closure of the courtroom for a hearing to determine whether the witness would testify did not violate Defendant’s right to a public trial; (2) trial counsel did not provide ineffective assistance; and (3) due to problems in the district judge’s decision to grant a downward durational departure, the case must be remanded for resentencing. View "State v. Reed" on Justia Law

This appeal concerned two unrelated cases. In the first case, Defendant pleaded guilty to burglary and misdemeanor theft. Defendant was eighteen years old when the crimes were committed. In the second case, Defendant pleaded guilty to aggravated indecent liberties with a child. Defendant was seventeen years old when the crime was committed. The district court authorized Defendant to be prosecuted as an adult. The cases were consolidated for pleas and sentencings. The district court sentenced Defendant to terms of imprisonment and to a lifetime of supervision once he was released from prison. The court of appeals affirmed, concluding that mandatory lifetime postrelease supervision for juveniles convicted of aggravated indecent liberties does not categorically constitute cruel and unusual punishment under the Eighth Amendment. The Supreme Court reversed, holding that mandatory lifetime postrelease supervision for juveniles who have committed and are later convicted of aggravated indecent liberties with a child is categorically unconstitutional. View "State v. Dull" on Justia Law

Defendant was convicted of driving while under the influence of alcohol and speeding. Defendant appealed both convictions and sought a trial de novo in district court, arguing that the evidence was the product of an illegal traffic stop. Specifically, Defendant argued that the officer who initiated the traffic stop did not have reasonable suspicion for the stop because the officer was mistaken about the applicable speed limit where a traffic sign normally posting the limit had been knocked to the ground. The Supreme Court affirmed, holding that the officer made a mistake of fact about the speed limit, but the mistake was objectively reasonable. View "City of Atwood v. Pianalto" on Justia Law

After a jury trial, Defendant was convicted of aiding and abetting first-degree premeditated murder, possession of cocaine with intent to distribute, and possession of marijuana. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion for new trial based on the State’s failure to disclose a plea agreement with the codefendant, as the plea agreement would not have changed the course of the trial by making the codefendant available to testify at trial; and (2) the district court’s failure to give a second-degree murder jury instruction was not clearly erroneous. View "State v. Soto" on Justia Law

After a jury trial, Defendant was convicted of capital murder based on his premeditated intentional killing of his ex-girlfriend and their one-year-old son. Defendant appealed, arguing that the trial court erred in denying his motion to suppress incriminating statements he made during two separate interrogations by law enforcement officers. The Supreme Court reversed, holding (1) the interrogating officers refused to terminate the questioning when Defendant invoked his rights under Miranda v. Arizona; and (2) because the error was not harmless, the district court erred in denying the suppression of Defendant’s statements made after the Miranda violation. View "State v. Aguirre" on Justia Law

Pursuant to a plea agreement, Appellant pleaded guilty to one count of attempted indecent solicitation of a child. The district court sentenced Appellant to eighteen months’ probation, with an underlying ten-month prison term and lifetime postrelease supervision. Appellant appealed, contending that lifetime postrelease supervision was disproportionate as applied to him, constituting cruel and/or unusual punishment in violation Section 9 of the Kansas Constitution Bill of Rights and the Eighth Amendment to the federal Constitution. The Court of Appeals affirmed. The Supreme Court affirmed, holding (1) Appellant abandoned his Eighth Amendment challenge on appeal for failure to adequately brief the issue; and (2) Appellant’s lifetime postrelease supervision term does not constitute cruel or unusual punishment under Section 9 of the Bill of Rights. View "State v. Funk" on Justia Law

Defendant was convicted of possession of marijuana with the intent to distribute and related offenses. On appeal, Defendant argued that the warrantless search of his cell phone conducted as a search incident to arrest violated his rights under the Fourth Amendment to the U.S. Constitution. The Court of Appeals affirmed. The Supreme Court reversed, holding (1) the search of Defendant’s cell phone violated the Fourth Amendment because Defendant did not unequivocally, specifically, and freely give consent for the officer to search the text messages on his cell phone, and Defendant’s consensual responses were not free from duress or coercion; and (2) the unlawful search of Defendant’s cell phone was not harmless. View "State v. James" on Justia Law

After a jury trial, Defendant was convicted and sentenced for first-degree premeditated murder. The Supreme Court affirmed, holding that the district court did not err by (1) concluding that Defendant was competent to stand trial after an adequate competency hearing and by failing to sua sponte order a second competency evaluation; (2) determining that Defendant’s confession to the police was voluntary; (3) limiting the defense voir dire of potential jurors regarding mental illness and mental disability; (4) overruling Defendant’s claim of insufficient evidence to support the murder conviction; (5) declining to give a lesser included offense instruction on voluntary manslaughter; and (6) ordering Defendant to register as a violent offender under the Kansas Offender Registration Act. View "State v. Woods" on Justia Law

Law enforcement officers employed by the City of Prairie Village set up a controlled drug buy from Defendant to occur in the City of Leawood. As a result of the controlled buy, the State charged Defendant with felony drug charges. Defendant moved to suppress the drugs and an audio recording of the controlled buy, arguing that the Prairie Village officers had obtained that evidence while exercising their police powers outside of their jurisdiction as authorized under Kan. Stat. Ann. 22-2401(a)(2). The district court granted the motion and suppressed the evidence. The court of appeals reversed, finding that the Prairie Village officers had jurisdiction in Leawood based on a provision in section 22-2401(a)(2)(b) allowing municipal officers to exceed their jurisdictional boundaries when another jurisdiction requests assistance. The Supreme Court affirmed on different grounds, holding (1) the statutory limitations on the jurisdiction of city officers was put in place to protect the local autonomy of neighboring cities and counties, rather than to create an individual right; and (2) consequently, the suppression of any evidence obtained during a city officer’s unauthorized exercise of police power outside the officer’s employing city will generally not be required. View "State v. Vrabel" on Justia Law

After a jury trial, Defendant was convicted of six drug offenses. The court of appeals affirmed in part and reversed in part, resulting in a reversal of one of Defendant’s convictions and the vacating of one of his sentences. Those issues were not before the Supreme Court for review. On appeal, Defendant sought the Court’s review of that portion of the court of appeals’ decision that was adverse to him. The Supreme Court affirmed, holding that the district court did not err in (1) denying Defendant’s motion to suppress evidence obtained from the warrantless search of his vehicle; (2) convicting Defendant for the separate offenses of possessing red phosphorous and iodine and possessing drug paraphernalia with intent to manufacture, as those convictions were not multiplicitous; and (3) using Defendant’s prior convictions to enhance his sentence. View "State v. Overman" on Justia Law