Justia Kansas Supreme Court Opinion Summaries

Defendant was convicted in two separate trials of first-degree premeditated murder in the death of Alfred Mack, second-degree intentional murder in the later death of Justin Letourneau, theft, and aggravated assault. Defendant appealed, raising several allegations of error. The Supreme Court reversed all of Defendant’s convictions under the cumulative error doctrine, holding (1) the district judge erred in excluding testimony about a statement Letourneau made in the hours before his death; (2) the jury instruction on alternative first-degree murder theories contained a misstatement of law with respect to reasonable doubt; (3) the district judge erred by not instructing the jury to begin its deliberations anew after one juror had been dismissed and replaced by an alternative juror; and (4) the district judge’s failure to recall some members of the jury when one juror raised the issue of jury misconduct after trial. View "State v. Smith-Parker" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder. The district court sentenced Defendant to a hard fifty sentence, which was imposed under Kan. Stat. Ann. 21-4635. The Supreme Court affirmed, holding (1) Defendant’s trial counsel did not provide ineffective assistance; (2) the district court did not err by admitting testimony concerning a confrontation between Defendant and the victim a few days before the murder, as the testimony was admissible under a hearsay exception to the general exclusionary rule; (3) the prosecutor did not engage in misconduct; but (4) because section 21-4635 has been found unconstitutional, Defendant’s hard fifty sentence was vacated and the case remanded to the district court for resentencing. View "State v. Coones" on Justia Law

Appellant pleaded no contest to premeditated first-degree murder, aggravated robbery, and forgery and was sentenced to life in prison, with no parole eligibility for twenty-five years. Nearly eleven years after her sentencing, Appellant filed a motion to withdraw her pleas because of manifest injustice, arguing that her lawyer misinformed her about the charges and possible penalties and that she did not understand the length of the prison sentence to which she could be subject if she entered the pleas. The district court denied the motion. The Supreme Court affirmed, holding that even if Appellant’s attorney misinformed or failed to fully inform Appellant of the charges and possible penalties, any prejudice from that error was cured by the judge’s thoroughness at the plea hearing. View "State v. Miles" on Justia Law

Appellant entered a no contest plea to one count of violating the Kansas Offender Registration Act. Appellant’s intensive supervision officer later filed a warrant alleging that Appellant had violated the terms of his probation. After a probation revocation hearing, the district court revoked Appellant’s probation and ordered him to serve the balance of his prison sentence. A panel of the court of appeals affirmed. Appellant then filed a pro se motion for postconviction relief under Kan. Stat. Ann. 60-1507 asserting that his counsel provided ineffective assistance at the probation revocation hearing. The district court denied the motion. A panel of the court of appeals affirmed, concluding that the prior panel had already rejected Appellant’s arguments and that the doctrine of res judicata barred Appellant’s present claim. The Supreme Court affirmed, holding (1) the court of appeals erred by applying the doctrine of res judicata to bar Defendant’s claim; but (2) the claim was meritless, and therefore, the lower courts did not err in denying Appellant’s motion. View "Grossman v. State" on Justia Law

Defendant was arrested for possession of cocaine and possession of drug paraphernalia. Defendant filed a motion to suppress the evidence obtained during a warrantless search of her vehicle conducted incident to a traffic stop. The district court granted the motion, concluding that the pretextual nature of the stop rendered the seizure constitutionally invalid. A divided court of appeals panel affirmed on other grounds, holding that the law enforcement officer did not have a reasonable suspicion that justified the search. The dissenting member of the panel argued that the case should be reversed and remanded for additional findings as to whether a reasonable suspicion existed, as an appellate court cannot engage in factfinding. The Supreme Court affirmed, holding that the evidence was properly suppressed, as (1) an appellate court conducts a de novo review of the totality of the circumstances to determine whether reasonable suspicion exists; (2) the undisputed facts and the district judge’s findings of fact were sufficient for appellate review of the totality of the circumstances; and (3) based on that review, the court of appeals correctly found that the search in this case was invalid because the circumstances did not establish a reasonable suspicion that justified a search of the vehicle. View "State v. Jones" on Justia Law

Appellant, a persistent sex offender involuntarily committed to Larned State Security Hospital, filed three petitions for writs of habeas corpus. Without requiring responses from the Secretary of the Kansas Department for Aging and Disability Services and without conducting hearings, the district court dismissed the petitions, concluding that Appellant’s failure to exhaust administrative remedies precluded habeas corpus relief. The court of appeals affirmed. The Supreme Court reversed, holding that the 2012 legislature expressly exempted habeas corpus proceedings from the exhaustion requirements of Kan. Stat. Ann. 59-29a24, and therefore, the district court erred in dismissing the petitions for failure to exhaust administrative remedies. View "Stanley v. Sullivan" on Justia Law

After a jury trial, Defendant was convicted of premeditated first-degree murder and aggravated burglary. Utilizing Kan. Stat. Ann. 21-4635, the sentencing judge imposed a sentence of life imprisonment without the possibility of parole for fifty years for Defendant’s murder conviction. Defendant appealed, arguing, among other things, that the sentencing judge erred in imposing a hard fifty sentence because section 21-4635, the hard sentencing statute in effect at the time of his sentencing, was unconstitutional. The Supreme Court affirmed Defendant’s convictions, vacated his hard fifty sentence, and remanded for resentencing, holding that section 21-4635 violates the Sixth Amendment because it imposes additional punishment based on factors not submitted to a jury and proven beyond a reasonable doubt. View "State v. Holt" on Justia Law

After a jury trial, Defendant was convicted of premeditated first-degree murder and two counts of aggravated assault. The district court found aggravating circumstances to impose a hard fifty life sentence on Defendant’s first-degree murder conviction. The Supreme Court affirmed the convictions but vacated Defendant’s sentence, holding (1) certain statements made by the prosecutor, although arguably misconduct, were very mild and made in response to defense counsel’s argument; (2) any error in failing to provide a second-degree murder instruction was harmless beyond a reasonable doubt; (3) cumulative error did not deny Defendant a fair trial; and (4) in accordance with State v. Soto, Defendant’s hard fifty sentence was unconstitutionally imposed by the district court in violation of Defendant’s Sixth Amendment right to a jury trial. Remanded for resentencing. View "State v. Roeder" on Justia Law

After a jury trial, Defendant was convicted of voluntary manslaughter and sentenced to 216 months’ imprisonment. The court of appeals affirmed on direct appeal. Defendant subsequently filed the present pro se motion for postconviction relief under Kan. Stat. Ann. 60-1507, alleging that his trial counsel was ineffective in three distinct ways. The district court denied the motion. The court of appeals affirmed. The Supreme Court reversed, holding that the district court erred by denying Defendant’s 60-1507 motion without an evidentiary hearing, as the motion, files, and records failed to show conclusively that Defendant was not entitled to relief. Remanded for an evidentiary hearing regarding Defendant’s allegations. View "Sola-Morales v. State" on Justia Law

The Attorney General alleged that the Chief Judge of the Tenth Judicial District exceeded his authority and contravened Kansas law by issuing an administrative order permitting marriage licenses to be issued to same sex couples. The Attorney General sought an order directing the Chief Judge and clerk of the district court to immediately cease from issuing marriage applications or licenses to same gender couples and an order vacating the Judge’s administrative order. The Supreme Court declined to grant the relief sought, as the Attorney General's right to relief on the merits was not clear, but granted the Attorney General’s alternative request for a temporary stay of the Chief Judge’s administrative order insofar as the order allows issuance of marriage licenses. The Court then requested additional briefing on the pending issues of whether the Chief Judge possessed authority to issue the administrative order and whether the interpretations and applications of the United States Constitution by the Tenth Circuit Court of Appeals are supreme and modify any Kansas state ban on same-sex marriage. View "State v. Moriarty" on Justia Law