Justia Kansas Supreme Court Opinion Summaries

In 1995, Appellant pleaded guilty to first-degree felony murder and aggravated robbery for crimes Appellant committed when he was fourteen years old. Approximately twelve years later, Appellant filed a pro se motion to withdraw his guilty pleas. Appellant also argued that his aggravated robbery sentence was illegal because his juvenile adjudications were used both to certify him for adult prosecution and to compute his criminal history score. The district court denied Appellant’s motion without conducting an evidentiary hearing. The Supreme Court affirmed, holding (1) Appellant failed to demonstrate the manifest injustice required by Kan. Stat. Ann. 22-3210(d) to withdraw his guilty pleas; and (2) Appellant’s aggravated robbery sentence, which was within the presumptive sentence for that crime based on Appellant’s criminal history score, was not illegal.View "State v. Kelly" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated indecent liberties with a child under the age of fourteen and was sentenced to concurrent life sentences without the possibility of parole for forty years. Defendant appealed, raising five issues relating to alleged trial errors and one issue relating to sentencing. The Supreme Court affirmed Defendant’s convictions and sentences, holding (1) Defendant failed to preserve several of his arguments by not making a timely objection to evidence or not creating a sufficient record for appeal; and (2) Defendant’s remaining arguments lacked merit. View "State v. Reed" on Justia Law

After a jury trial, Defendant was found guilty of premeditated first-degree murder. The Supreme Court affirmed on appeal. Defendant subsequently filed a habeas corpus action alleging, inter alia, that his appellate counsel provided ineffective assistance for failing to challenge an incorrect written jury instruction that diluted the State’s burden to prove guilt beyond a reasonable doubt. The court of appeals reversed Defendant’s conviction and remanded his case for a new trial. The Supreme Court affirmed, holding that appellate counsel’s failure to challenge the incorrect instruction was objectively unreasonable and prejudicial, and therefore, Defendant was entitled to a new trial.View "Miller v. State" on Justia Law

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