Justia Kansas Supreme Court Opinion Summaries

Defendant Mauricio Macias-Medina pled guilty to aggravated indecent liberties with a child pursuant to a plea agreement. After entering his plea but before sentencing, Defendant filed a motion to withdraw his guilty pleas, contending that his attorney and his interpreter had coerced him into accepting the plea agreement. The district court denied Defendant's motion, determining that Defendant's pleas were knowingly and intelligently made and that they were not caused by dishonest interpretation of information or by coercion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in finding an absence of good cause to permit Defendant to withdraw his pleas. View "State v. Macias-Medina" on Justia Law

Katreal Harris was convicted of first-degree murder, attempted second-degree murder, and criminal possession of a firearm. The Supreme Court affirmed, holding that the district court did not abuse its discretion by (1) failing to instruct the jury on the lesser included offenses of voluntary manslaughter and attempted voluntary manslaughter based on a theory of imperfect self-defense; (2) denying Harris' motion to suppress statements made to police where the statements were voluntary; (3) denying Harris' motion for mistrial during jury selection where there was no showing of substantial prejudice; (5) imposing a hard fifty sentence without first submitting the aggravating factors to a jury for proof beyond a reasonable doubt; and (6) including Harris' prior juvenile adjudication in his criminal history without a jury determination. View "State v. Harris" on Justia Law

Katrina Allen pleaded guilty to attempted possession of methamphetamine pursuant to a plea agreement but did not appear for her scheduled sentencing hearing as ordered pursuant to the plea agreement. Allen eventually appeared in court, but the district court released the State from its plea obligation to recommend probation at sentencing. The court of appeals affirmed. Allen appealed, arguing that the district court erred in releasing the State from its obligations because she substantially complied with her obligations under the plea agreement. The Supreme Court affirmed without reaching the merits of Allen's argument, as Allen failed to address a dispositive procedural holding of the court of appeals in her petition. View "State v. Allen" on Justia Law

Oscar Torres pleaded guilty to felony murder, criminal discharge of a firearm at an occupied building, and aggravated assault. After the Supreme Court remanded the case for resentencing on a separate issue but before resentencing, Torres sought to withdraw his plea. Torres argued that the State violated the plea agreement at his original, since-vacated sentencing by reading a letter from the victim's mother asking the court to impose the maximum prison time. The Supreme Court affirmed, holding that because Torres ultimately received a new sentencing hearing at which the victim's mother personally testified and the court imposed the sentence recommended by the plea agreement, Torres' argument on appeal was moot. View "State v. Torres" on Justia Law

Appellant Roland Guder pleaded guilty to unlawfully manufacturing a controlled substance, cultivating marijuana, criminally possessing a weapon, and possessing drug paraphernalia. The court of appeals vacated reversed the original sentence for manufacturing a controlled substance and remanded with directions to resentence Appellant. The district court modified the manufacturing sentence as it was directed to do by the court of appeals but also modified the paraphernalia sentence. At issue on appeal was whether a district court could modify a previously imposed sentence on one conviction following a remand from an appellate court for resentencing based on a different conviction. The Supreme Court vacated the sentence the modification of Appellant's paraphernalia sentence and remanded for resentencing, holding that a district court is not allowed to modify any of the sentences that were not vacated on appeal. View "State v. Guder" on Justia Law

Montrez Washington was convicted of first-degree felony murder and attempted aggravated robbery. Washington appealed, arguing that (1) insufficient evidence was presented at his preliminary hearing, and (2) the Allen-type jury instruction given at his trial was clearly erroneous. The Supreme Court affirmed, holding (1) the evidence presented at Washington's preliminary hearing was sufficient to bind him over for trial, and (2) the Allen-type instruction was not clearly erroneous under the facts of this case where the instruction was included in the jury instructions given before jury deliberations and there was no indication the instruction changed the outcome of the trial. View "State v. Washington" on Justia Law

Subsequent to the sentencing hearing at which Appellant Justin Jones was sentenced for committing the crime of aggravated indecent liberties with a child, the Supreme Court filed several decisions that explained the steps to be taken if a sentencing court departed from the sentence provided for in Jessica's Law. The sentencing court did not explicitly take these steps or make the corresponding findings. As a result, under these recent decisions, Appellant's sentence would be considered illegal. The State argued that Appellant could not complain about his sentence because he had agreed to the sentence as part of a plea agreement. The Supreme Court vacated Appellant's sentence, noting that a defendant cannot agree to an illegal sentence. Remanded for resentencing. View "State v. Jones" on Justia Law

Shannon Bogguess requested a bench trial on stipulated facts after his motion to suppress his confession was denied. Bogguess was subsequently convicted of first-degree murder, aggravated robbery, aggravated kidnapping, aggravated assault, and criminal possession of a firearm. The Supreme Court affirmed in part and dismissed in part, holding, inter alia, that (1) Bogguess reserved his right to appeal while proceeding to a bench trial on stipulated facts even through he did not do so expressly; (2) at the Jackson v. Denno hearing to determine whether Bogguess' confession was voluntary, the district court erred in ruling that Bogguess must answer questions about events that were the bases for the crimes charged, and the court erred in striking all of Bogguess' testimony after he refused to testify further because Bogguess had a valid Fifth Amendment privilege; and (3) the district court did not err in denying Bogguess' motion to suppress. View "State v. Bogguess" on Justia Law

After a jury trial, Willie Dale was convicted of attempted first-degree murder, aggravated robbery, and aggravated assault. The court of appeals affirmed. The Supreme Court granted Dale's petition for review on the single issue of whether the district court erred in admitting a slow motion version of a patrol-car video. The Supreme Court affirmed, holding (1) because the best evidence, namely the original video, had already been admitted at trial, and the modified video was not introduced to prove or disprove the content of the original video, the video's admission did not violate the best evidence rule; and (2) because the video was not unduly repetitious and added something to the State's case, its admission was not cumulative. View "State v. Dale" on Justia Law

Anthony Kidd was convicted of first-degree murder, aggravated assault, criminal discharge of a firearm at an occupied dwelling, and aggravated battery. Kidd appealed. The Supreme Court affirmed, holding, (1) the district court did not err in refusing to instruct the jury on the defense of voluntary intoxication; and (2) the prosecutor violated his duty to inform the State that an order in limine prohibited reference to Kidd's prior crimes, but this error and one witness's subsequent violation of that order did not affect the outcome of the trial, and therefore, the error was harmless. The Court rejected Kidd's remaining claims. View "State v. Kidd" on Justia Law