Justia Kansas Supreme Court Opinion Summaries

The State charged Defendant with one count of aggravated indecent liberties with a child under fourteen years old. The district court accepted Defendant’s no contest plea. At the sentencing hearing, Defendant sought to withdraw his plea. The district court denied Defendant’s motion and proceeded to sentencing. Defendant appealed. At issue before the Supreme Court was whether the district court erred by failing to inquire regarding an alleged conflict of interest between Defendant and his counsel and by failing to appoint conflict-free counsel to represent Defendant at the motion to withdraw plea and sentencing hearing. The Supreme Court reversed the district court’s denial of Defendant’s motion to withdraw his plea and vacated the sentence, holding (1) under the circumstances of this case, Defendant and his counsel alerted the trial court to a potential conflict between them, and the district court erred by failing to inquire further into the nature of that conflict; and (2) Defendant was denied effective assistance of counsel because he was not provided conflict-free counsel to assist him in arguing his motion to withdraw his plea. Remanded. View "State v. Prado" on Justia Law

After a jury trial, Defendant was found guilty of one count of premeditated first-degree murder and one count of aggravated assault. The district court sentenced Defendant to a hard fifty life sentence for the murder conviction. Defendant appealed, arguing, among other things, that the procedure used to impose his sentence violated his constitutional right to a trial by jury. The Supreme Court affirmed the convictions but vacated the hard fifty sentence, holding that because the district court, rather than a jury, found the existence of an aggravating circumstance, the district court violated Defendant’s Sixth Amendment right to a jury trial. Remanded for resentencing. View "State v. Hayes" on Justia Law

Defendant was charged with involvement with a theft. Defendant moved to suppress evidence obtained through a search warrant authorizing the seizure of his biological material. The district court denied the motion to suppress, and Defendant was subsequently convicted of felony theft and felony criminal damage to property. The court of appeals affirmed the district court’s denial of Defendant’s motion to suppress. The Supreme Court reversed Defendant’s convictions, holding that it was objectively unreasonable for the officer to rely on the warrant , and therefore, the district court erred by applying the United States v. Leon good-faith exception to the exclusionary rule after finding the warrant lacked the required probable cause. Remanded. View "State v. Powell" on Justia Law

Two days after Defendant’s arrest for marijuana possession, the United States Supreme Court decided Arizona v. Gant, which invalidated certain searches incident to arrest. Defendant moved to suppress the drug evidence pursuant to Gant. The district court granted the motion, concluding that a good-faith exception did not apply in this case. While Defendant’s appeal was pending, the Supreme Court issued its opinion in State v. Daniel, which held that an officer’s pre-Gant search incident to a lawful arrest was subject to the good-faith exception to the exclusionary rule based on the officer’s objectively reasonable reliance on Kan. Stat. Ann. 22-2501. Defendant argued that the good-faith exception should not apply in his case because the search exceeded the physical scope permitted by section 22-2501. The court of appeals affirmed. The Supreme Court reversed, holding that the State’s arguments did not justify application of a good-faith exception to the plain language of section 22-2501. View "State v. Pettay" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree premeditated murder and one count of criminal possession of a firearm. Defendant was sentenced to life in prison without the possibility of parole for fifty years (hard fifty) on the murder conviction. The Supreme Court affirmed Defendant’s convictions but vacated his hard fifty sentence, including the district court’s unauthorized imposition of lifetime postrelease supervision, holding that Defendant’s hard fifty life sentence was unconstitutional under Alleyne v. United States and State v. Soto and that the district court erred in imposing lifetime postrelease supervision for Defendant’s off-grid convictions. View "State v. Molina" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, felony murder, and abuse of a seventeen-month-old child. Defendant was sentenced to life without possibility of parole for fifty years (hard fifty). The Supreme Court affirmed Defendant’s convictions but vacated his hard fifty life sentence, holding that the hard fifty sentencing procedure set out in Kan. Stat. Ann. 21-4635 was unconstitutional under Alleyne v. United States and State v. Soto because the sentencing scheme permitted a judge, rather than a jury, to find aggravating circumstances necessary to impose an increased mandatory minimum sentence in violation of the Sixth Amendment to the United States Constitution. View "State v. Lloyd" on Justia Law

After a jury trial, Defendant was convicted of premeditated first-degree murder, conspiracy to commit first-degree murder, and criminal possession of a firearm. Defendant appealed, raising a number of issues. The Supreme Court affirmed, holding (1) the prosecutor committed misconduct during closing argument by misstating the legal definition of “premeditation,” but this misstatement did not deprive Defendant of a fair trial and was therefore harmless; (2) the evidence was sufficient to support the convictions; (3) the trial court did not err in its evidentiary rulings or in its instructions to the jury; (4) Defendant’s constitutional rights were not violated because of witness and juror misconduct or by the State’s exercise of its peremptory challenges; and (5) cumulative errors did not deprive Defendant of a fair trial. View "State v. Williams" on Justia Law

After his first trial ended with a hung jury, Defendant was retried and convicted of premeditated first-degree murder, conspiracy to commit first-degree murder, and criminal possession of a firearm. The Supreme Court affirmed on direct appeal from Defendant’s second trial, holding (1) the trial court did not violate Defendant’s right to be protected from double jeopardy by allowing him to be retried for the same crimes without formally ordering a mistrial at the conclusion of his first trial; (2) there was sufficient evidence to affirm Defendant’s murder conviction; and (3) the prosecutor committed misconduct during closing argument by misstating the legal definition of “premeditation,” but this misstatement did not deprive Defendant of a fair trial. View "State v. Phillips" on Justia Law

After a jury trial, Defendant was convicted of premeditated first-degree murder, conspiracy to commit first-degree murder, and criminal possession of a firearm. Defendant appealed, raising four assignments of error. The Supreme Court affirmed, holding (1) the prosecutor committed misconduct during closing argument by misstating the legal definition of “premeditation,” but this misstatement did not deprive Defendant of a fair trial; (2) the State’s exercise of peremptory challenges to strike African-Americans from the jury panel did not violate the Equal Protection Clause; and (3) there was sufficient evidence to support Defendant’s convictions for premeditated first-degree murder and conspiracy to commit-first-degree murder. View "State v. Kettler " on Justia Law

Defendant pleaded guilty to first-degree premeditated murder and was sentenced to life without the possibility of parole for fifty years. The Supreme Court vacated Defendant’s sentence, holding that the state’s former statutory procedure for imposing a hard fifty sentence as utilized in this case violated the Sixth Amendment to the federal Constitution as interpreted in Alleyne v. United States because it permitted a judge to find by a preponderance of the evidence the existence of one or more aggravating factors necessary to impose an increased mandatory minimum sentence, rather than requiring a jury to find the existence of the aggravating factors beyond a reasonable doubt. Remanded for resentencing. View "State v. DeAnda" on Justia Law