Justia Kansas Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of premeditated first-degree murder. The Supreme Court affirmed, holding (1) Defendant was not entitled to an instruction on self-defense; (2) the district court did not commit clear error by failing to instruct on second-degree intentional murder; (3) the prosecutor committed misconduct during closing arguments by vouching for the credibility of some witnesses, discussing facts not in evidence, and disparaging the defense, but the statements did not deprive Defendant of a fair trial; (4) the district court did not err in excluding evidence suggesting that a third party might have had a motive to commit the murder; (5) Defendant did not preserve his argument that the district court violated his confrontation rights by limiting cross-examination of a state witness; and (6) the presumed instructional error and the instances of prosecutorial misconduct did not cumulatively deny Defendant a fair trial. View "State v. Knox" on Justia Law

While fleeing the police during a high-speed chase, Defendant collided with another vehicle, killing both occupants. After a jury trial, Defendant was convicted of two counts of first-degree felony murder and one count of fleeing or attempting to elude a police officer. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by urging defense counsel to complete voir dire or setting a time limitation on the second day; (2) the district court’s remark in the jury’s presence about the time defense counsel was taking during voir dire was not improper or prejudicial; (3) the district court did not err in refusing to change venue; (4) the prosecutor made a misstatement as to the process for considering lesser included offenses, but the misstatement did not so prejudice the jury as to deny Defendant a fair trial; and (5) the State properly charged felony murder rather than involuntary manslaughter while driving under the influence. View "State v. Hudgins" on Justia Law

Defendant pled guilty to one count of first-degree murder. Just over one year later, the clerk of the district court received a pro se motion for postconviction relief pursuant to Kan. Stat. Ann. 60-1507, in which Defendant alleged that he received ineffective assistance of counsel. Defendant filed his supporting memorandum less than one month later. The district court summarily denied the motion, concluding that Defendant had waived his right to file a section 60-1507 motion based on the purported ineffective assistance of counsel and that the motion was time-barred. The Court of Appeals affirmed but on different grounds, concluding that Defendant’s supporting memorandum should be treated as an attempted section 60-1507 amendment and that the amendment was time-barred. The Supreme Court reversed, holding (1) the district court erred by concluding that Defendant waived his right to file a section 60-1507 motion alleging ineffective assistance of counsel; (2) the district court erred by concluding that Defendant failed to file his section 60-1507 motion within the one-year time limitation in Kan. Stat. Ann. 60-1507(f)(1); and (3) the Court of Appeals erred in affirming the district court’s dismissal after treating the supporting memorandum as an untimely amendment. Remanded. View "Wahl v. State" on Justia Law