Justia Kansas Supreme Court Opinion Summaries

Defendant pleaded guilty to first-degree murder, aggravated kidnapping, aggravated robbery, and a weapons violation when he was seventeen. The district court judge sentenced Defendant to life in prison on each of the first two counts, fifteen years to life on the third count, and five years on the fourth count, with all of the sentences to run consecutively. Defendant appealed his sentences. The Supreme Court affirmed, holding (1) Defendant's claim that his sentences were the products of judicial bias, prejudice, or corrupt motive failed on appeal; and (2) the district court judge did not err by considering the results of Defendant's psychological examination during sentencing, and the judge's consideration of statements Defendant made during the examination without having been given Miranda warnings beforehand was not error, as Miranda warnings were unnecessary in this case. View "State v. Schaeffer" on Justia Law

Appellant pled nolo contendere to and was convicted of a second drug offense that required his participation in a mandatory drug treatment program. Appellant was sentenced to an underlying prison term of eleven months and placed on eighteen months' probation. Appellant failed to comply with the terms of his probation, prompting the district court to revoke his probation and order him to serve his eleven-month prison sentence. Appellant appealed, claiming that the district court should have imposed a different sanction for his probation violation. By the time the matter came before the court of appeals, Appellant had completed his prison sentence and had been released from State custody and supervision. The court of appeals dismissed the appeal as moot. The Supreme Court affirmed, holding that Appellant failed to refute the State's contention that the actual controversy had ceased or to establish an exception to the general rule that precludes appellate review of moot issues. View "State v. Montgomery" on Justia Law

In 2002, a jury convicted Appellant of premeditated first-degree murder and rape for acts committed two decades earlier, in 1982. Appellant was sentenced to life in prison. In 2007, Appellant filed a pro se petition for DNA testing pursuant to Kan. Stat. Ann. 21-2512, asserting that prior DNA test results were incompetent for a number of reasons. The district court summarily denied Appellant's petition, determining that the DNA evidence was properly offered and admitted by the court, that the DNA techniques used by the State were representative of the latest techniques available, and that Appellant's petition failed to state a cause of action upon which relief could be granted pursuant to section 21-2512. The court of appeals affirmed. The Supreme Court reversed, holding that Appellant's petition satisfied the criteria pursuant to section 21-2512. Remanded for an evidentiary hearing with appointed counsel. View "State v. Lackey" on Justia Law

Appellant was sentenced to serve two consecutive twelve-month probation terms for her convictions in two separate criminal cases. During the first term, the district court revoked both probations and ordered Appellant to serve her underlying prison sentences. Appellant appealed, claiming that the second probation term had not commenced when she violated the terms of the first probation term, so that the district court erred in sending her to prison on the second case. Appellant completed serving her prison terms before the case could be heard on appeal, and the court of appeals dismissed the appeal as moot. Finding that the issue raised by Appellant was one capable of repetition and of importance, the Supreme Court reversed and remanded to the court of appeals to reinstate the appeal. View "State v. Hilton" on Justia Law

After a jury trial, Appellant was convicted of rape and aggravated indecent liberties with a child. Appellant appealed, arguing, among other things, that the district court erred by imposing lifetime postrelease supervision instead of parole and by imposing electronic monitoring as a parole condition. The Supreme Court (1) affirmed Appellant's convictions; (2) vacated that portion of Appellant's sentence imposing postrelease supervision for the rape conviction, as the district court should have only sentenced Appellant to a life sentence with no parole for twenty-five years for the conviction, not lifetime postrelease supervision, and remanded to the district court for a nunc pro tunc order to correct a portion of the journal entry to delete reference to electronic monitoring, as the sentencing court did not have authority to impose such parole conditions; and (3) affirmed the remainder of Appellant's sentence. View "State v. Beaman" on Justia Law

Appellant was convicted of first-degree murder and criminal possession of a firearm for shooting and killing Keith Peters after Keith attempted to break up a fight between two rival gangs. Appellant appealed, asserting that the district court erred in (1) instructing the jury it could consider his gang membership, (2) giving an outdated eyewitness identification instruction he requested, and (3) failing to give a lesser included offense instruction, despite his request that the instruction not be given. The Supreme Court affirmed Appellant's convictions, holding (1) the district court did not err in giving a limiting instruction regarding gang evidence; and (2) the doctrine of invited error precluded Appellant's remaining challenges. View "State v. Jones" on Justia Law

Following his plea of guilty to aggravated indecent liberties with a child, Appellant was sentenced to 216 months' imprisonment. The court also granted a downward departure to thirty-six months' probation to be served at a community corrections residential center. Less than a week after completing the residential portion of his probation, Appellant violated his probation. After a hearing, the court revoked Appellant's probation and reimposed Appellant's original sentence. The court of appeals affirmed. The Supreme Court reversed, holding that the district court abused its discretion in stating that statutory restrictions limited its authority to impose a lesser sentence, which was an incorrect legal standard. Remanded for resentencing. View "State v. Ardry" on Justia Law

This appeal followed a district court's denial of a defendant's motions for new trial based on postconviction DNA testing that was allowed under Kan. Stat. Ann. 21-2512. The postconviction DNA testing produced some results that were favorable to the defendant, some results that confirmed evidence at trial, and some results that were inconclusive because the small amount and the degradation of the DNA prevented DNA matching. Weighing the mixed results of this evidence, the district court concluded there was not a reasonable probability that the new evidence would have changed the outcome of the trial. The Supreme Court affirmed after noting that an abuse of discretion standard of review applies when the issue on appeal is whether a district court erred in ruling on a motion for new trial based on favorable postconviction DNA test results, holding that reasonable people could agree with the district court that the postconviction DNA test evidence was not so material as to make it reasonably probable there would be a different outcome if there were a new trial. View "Haddock v. State" on Justia Law

A jury convicted Defendant of premeditated first-degree murder, aggravated burglary, burglary, and criminal possession of a firearm. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting an audio recording of a 911 call made by the murder victim's wife; (2) the district court did not abuse its discretion in admitting evidence of seven uncharged burglaries allegedly committed by Defendant for the purposes of proving identity and plan under Kan. Stat. Ann. 60-455; (3) the prosecutor did not commit reversible misconduct; (4) the sentencing court appropriately imposed a hard 50 sentence; and (5) the hard 50 sentencing scheme is constitutional. View "State v. Wilson" on Justia Law

After a jury trial, Defendant was convicted of aggravated indecent liberties. Defendant appealed, challenging the sufficiency of the evidence of his conviction on several grounds. The Supreme Court reversed Defendant's conviction, holding that the evidence was insufficient to support the conviction of aggravated indecent liberties because (1) the State presented no evidence that Defendant engaged in any lewd fondling or touching of the complainant or himself, done or submitted to with the intent to arose or satisfy the sexual desires of the complainant, Defendant, or both; and (2) the State failed to present any evidence, much less sufficient evidence, that Defendant "submitted to lewd fondling or touching" as specified in the jury instruction. View "State v. Warren" on Justia Law