Justia Kansas Supreme Court Opinion Summaries

Police responded to a domestic disturbance at a home shared by the defendant, his partner, and their children. During the incident, officers found a rifle in the living room. The defendant admitted ownership of the firearm and acknowledged he was on probation. Several months earlier, he had pled guilty to misdemeanor domestic battery, a conviction that, under Kansas law, prohibited him from possessing a firearm for five years. The defendant was charged with felony criminal use of a weapon for knowingly possessing a firearm within five years of his domestic violence conviction.In the Sedgwick District Court, the defendant moved to dismiss the charge, arguing that the statute prohibiting firearm possession by those convicted of misdemeanor domestic violence offenses violated the Second Amendment. The district court denied the motion, and the defendant was convicted by a jury. On appeal, the Kansas Court of Appeals affirmed the conviction, holding that the statute was constitutional and that sufficient evidence supported the verdict.The Supreme Court of the State of Kansas reviewed the case to address the Second Amendment challenge. The court held that the Kansas statute, which temporarily disarms individuals convicted of misdemeanor domestic violence offenses, is consistent with the nation’s historical tradition of firearm regulation. The court reasoned that early American laws, such as surety and “going armed” laws, allowed for the disarmament of individuals who posed a threat of violence, and that a recent conviction for domestic violence is sufficient to establish such a threat. The court concluded that the statute imposes a narrow, temporary restriction and is constitutional both on its face and as applied. The Supreme Court of Kansas affirmed the decisions of both the Court of Appeals and the district court. View "State v. McCray " on Justia Law

A sheriff’s deputy in Geary County, Kansas, stopped a vehicle driven by Brian Beck after observing that a license plate frame partially obscured the state name on the plate. Beck was not committing any driving infractions. During the stop, Beck appeared nervous and gave an unusual explanation for his travel route. A canine unit was called, and after the dog alerted, Beck consented to a search of his car, which led to the discovery of over two pounds of methamphetamine. Beck was charged with possession with intent to distribute, possession without a drug tax stamp, and interference with law enforcement. He moved to suppress the evidence, arguing the stop was not supported by reasonable suspicion, but the Geary District Court denied the motion. At trial, Beck renewed his objection, which was again overruled, and a jury convicted him on all counts.On appeal, the Kansas Court of Appeals affirmed the convictions, holding that the partial obstruction of the state name justified the stop under Kansas law, specifically K.S.A. 8-133, which requires license plates to be “clearly visible” and “clearly legible.” The appellate panel reasoned that covering half of the state name violated the statute, regardless of whether the plate could otherwise be identified.The Supreme Court of the State of Kansas reviewed only the statutory interpretation issue. It held that Kansas law does not require the state name to be clearly legible on license plates, except as it appears on registration decals. The court found that the lower courts had misapplied the statute by treating the obscured state name as a violation. The Supreme Court reversed the decisions of both the district court and the Court of Appeals on this issue and remanded the case for further proceedings consistent with its interpretation of the statute. View "State v. Beck " on Justia Law

A prospective employee applied for a position as an occupational therapist with a rehabilitation company, which required COVID-19 vaccination as a condition of employment. The applicant requested a religious exemption, submitting a written statement and a supporting letter from a friend citing religious objections to vaccines developed with fetal cell lines. The company questioned the applicant about her vaccination history and, finding her responses insufficiently sincere, denied the exemption and rescinded the job offer. The applicant filed a complaint with the Kansas Department of Labor, which found the company had violated Kansas law by inquiring into the sincerity of her religious beliefs.The company sought judicial review in the Johnson District Court, which reversed the agency’s decision. The district court held that the relevant Kansas statute, which prohibits employers from inquiring into the sincerity of an employee’s religious beliefs when considering COVID-19 vaccine exemptions, was preempted by federal law—specifically, the federal Vaccine Mandate for Medicare and Medicaid providers and Title VII of the Civil Rights Act. The district court also found the Kansas statute violated due process because it lacked a rational basis.On appeal, the Supreme Court of the State of Kansas reviewed the case de novo. The court held that the federal Vaccine Mandate and Title VII do not expressly or impliedly preempt the Kansas statute, because federal law permits but does not require employers to inquire into religious sincerity. The court further held that the Kansas law does not violate due process, as it is rationally related to the legitimate state interest of protecting religious liberty and provides adequate procedural protections. The Supreme Court of Kansas reversed the district court’s judgment and remanded the case for further proceedings. View "Powerback Rehabilitation v. Dept. of Labor" on Justia Law

In November 2016, D.J., then 15 years old, was involved in a marijuana transaction that resulted in the shooting death of J.S. The State charged D.J. with felony murder, aggravated robbery, and possession of marijuana. D.J. agreed to plead no contest in exchange for the case being designated as an extended jurisdiction juvenile prosecution (EJJP) rather than being tried as an adult. The court sentenced D.J. to a juvenile correctional facility until he was 22 years, 6 months old, with an adult sentence of life without parole for 25 years for the felony murder count, among other penalties, stayed as long as D.J. complied with his juvenile sentence.In October 2021, D.J. was released on conditional release but was later found in a vehicle with firearms and marijuana, and in July 2022, he was caught driving without a license and possessing marijuana. The State moved to revoke D.J.'s juvenile sentence, and the district court found that D.J. had violated the conditions of his juvenile sentence by possessing firearms and marijuana and eluding law enforcement.The Kansas Supreme Court reviewed the case and affirmed the district court's decision. The court held that substantial competent evidence supported the revocation of D.J.'s juvenile sentence. The court also held that under K.S.A. 38-2364, the district court was required to revoke the juvenile sentence and impose the adult sentence upon finding a violation of the juvenile sentence. The court rejected D.J.'s arguments that the district court had discretion to continue the stay of the adult sentence and that the district court could modify the adult sentence under K.S.A. 22-3716.The court also dismissed D.J.'s constitutional proportionality claims, stating that case-specific challenges could not be raised for the first time on appeal and that D.J. failed to comply with Supreme Court Rule 6.02(a)(5) for his categorical challenge. Finally, the court declined to review D.J.'s ineffective assistance of counsel claim due to the lack of a Van Cleave hearing and insufficient factual development in the record. View "In re D.J. " on Justia Law

The State filed a petition alleging that A.K., a three-year-old child, was in need of care. Both parents entered no contest statements, and the court found A.K. to be a child in need of care. The father later died, leaving the mother as the sole subject of the termination proceedings. The State filed a motion to terminate the mother's parental rights, and during a pretrial conference, the mother did not appear, but her attorney did. The court set a date for a "proffer trial" under K.S.A. 38-2248(f). At the proffer trial, the mother was absent, and her attorney objected to proceeding by proffer, leading the court to set a full trial date. The mother did not appear at the trial, and her substitute counsel did not object to proceeding by proffer. The court terminated the mother's parental rights based on the State's proffer of evidence.The Johnson District Court terminated the mother's parental rights based on the State's proffer of evidence. The mother appealed, arguing that the court had no authority to proceed by proffer because she had instructed her counsel to object. She also argued that K.S.A. 38-2248(f) violated procedural due process. The Court of Appeals affirmed the district court's decision, rejecting the mother's claims.The Kansas Supreme Court reviewed the case and held that the district court misapplied K.S.A. 38-2248(f) by terminating the mother's parental rights based on a proffer alone. The court clarified that while K.S.A. 38-2248(f) permits a proffer against an absent party who has not instructed their counsel to object, it does not allow the district court to make a finding of unfitness or terminate parental rights based solely on the proffer. The court reversed the judgments of both the Court of Appeals and the district court and remanded the case for further proceedings. View "In re A.K. " on Justia Law

A three-year-old child, C.V., died in February 2019 while in the care of his mother’s domestic partner, Uraquio Arredondo, in Ulysses, Kansas. On the day of the incident, C.V. was behaving normally until left alone with Arredondo. Later that day, Arredondo called 911, reporting that C.V. had been in an accident. Emergency responders found C.V. unresponsive with extensive bruising. Medical examinations revealed that C.V. died from multiple blunt force injuries, including a fresh skull fracture and internal bleeding, with evidence of both recent and older injuries. Testimony from the daycare provider and C.V.’s father indicated prior signs of abuse, with C.V. attributing some injuries to Arredondo.The State charged Arredondo with felony murder and child abuse. He waived his right to a jury trial, and the Grant District Court judge found him guilty on both counts, imposing a life sentence for murder and a consecutive sentence for child abuse. During the investigation, law enforcement entered Arredondo’s residence three times without a warrant. Arredondo challenged the admissibility of evidence from the second and third entries, arguing lack of valid consent and coercion. He also sought to suppress his statements to law enforcement, claiming they were involuntary and made without Miranda warnings, but he had not objected to their admission at trial.The Supreme Court of the State of Kansas reviewed the case. It held that the second and third entries into the residence were lawful because Arredondo voluntarily consented to both searches, and the police lawfully secured the home based on probable cause. The court also found that Arredondo failed to preserve his challenge to the admissibility of his statements for appellate review. Finding no error, the court affirmed Arredondo’s convictions. View "State v. Arredondo " on Justia Law

Brian Stubbs was convicted of criminal use of a weapon and interference with law enforcement after an incident where he stabbed Edward McCutcheon with a large kitchen knife. Stubbs arrived uninvited at McCutcheon's apartment, leading to a fight. McCutcheon was seriously injured, and Stubbs fled the scene. Police pursued Stubbs, who ignored commands to stop, leading to his arrest.The Douglas District Court convicted Stubbs of criminal use of a weapon and interference with law enforcement. Stubbs appealed, arguing that the statute under which he was convicted was unconstitutionally vague and that there was insufficient evidence to support his conviction for interference with law enforcement. The Kansas Court of Appeals affirmed the district court's decision, holding that Stubbs lacked standing to challenge the statute's vagueness because he did not show it was vague as applied to his conduct.The Kansas Supreme Court reviewed the case and held that Stubbs had standing to bring an arbitrary-enforcement challenge to the statute. The court explained that such challenges are inherently facial because they dispute the legislature's authority to enact the statute at all. The court found that Stubbs' conviction under the allegedly void statute presented a concrete injury, satisfying the standing requirements.On the merits, the Kansas Supreme Court held that the statute's prohibition on possessing a "dangerous knife" with intent to use it "unlawfully against another" provided adequate enforcement guidelines. The court concluded that the statute did not invite arbitrary or discriminatory enforcement. Additionally, the court found sufficient evidence to support Stubbs' conviction for interference with law enforcement, as the jury could reasonably conclude that Stubbs knowingly obstructed the officer's duties. The court affirmed the judgments of both the Court of Appeals and the district court. View "State v. Stubbs " on Justia Law

Two Wichita police officers stopped Gina Wilson after observing her fail to signal properly. Wilson admitted her license was suspended and refused consent to search her vehicle. Officers called for a K-9 unit, which arrived nine minutes later. The dog, Oden, indicated the presence of drugs, leading officers to search the car and find 30 oxycodone pills. Wilson was arrested and charged with possession of an opiate and driving while suspended.Wilson moved to suppress the evidence, arguing the search violated the Fourth Amendment. The Sedgwick District Court denied the motion, finding no constitutional violation as the stop was not meaningfully extended. A jury convicted Wilson. The Kansas Court of Appeals affirmed, agreeing that the dog sniff did not extend the stop's duration and thus did not violate the Fourth Amendment.The Kansas Supreme Court reviewed the case, focusing on whether the search was permissible under the Fourth Amendment. The court held that a drug dog's sniff of a vehicle's exterior is not a search under the Fourth Amendment. Since Wilson's car was legally parked and she admitted to driving with a suspended license, the officers had probable cause to search the vehicle based on the dog's alert. The court affirmed the lower courts' rulings, concluding the search was constitutional and the evidence was properly admitted. View "State v. Wilson " on Justia Law

Clyde James Barnes Jr. was convicted by a jury of first-degree premeditated murder, aggravated burglary, tampering with electronic monitoring equipment, criminal threat, and violation of a protective order. The case arose after Barnes, who was on house arrest, tampered with his GPS ankle bracelet and traveled to the residence of his ex-partner, Jessica Leigh Smith. Barnes broke into Smith's home and brutally murdered her with a mattock. The crime was captured on surveillance cameras, and forensic evidence linked Barnes to the scene.The Johnson County District Court found Barnes guilty on all counts and sentenced him to life imprisonment with a mandatory minimum of 620 months for the murder, plus additional consecutive sentences for the other charges. Barnes appealed, raising several issues, including the constitutionality of the territorial jurisdiction statute under which he was prosecuted for tampering with electronic monitoring equipment, claims of prosecutorial error, the admission of graphic photographs, the jury instructions on premeditation, and the sufficiency of the evidence for the tampering conviction.The Kansas Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the district court had subject matter jurisdiction over the tampering charge under K.S.A. 21-5106(b)(3), as the proximate result of Barnes' tampering occurred in Kansas. The court also found no prosecutorial error in the closing arguments, determining that the prosecutor's statements were fair comments on the evidence. The court ruled that the admission of the photographs was not an abuse of discretion, as they were relevant and not unduly prejudicial. The court upheld the premeditation jury instruction, finding it accurately stated the law. Finally, the court concluded that sufficient evidence supported Barnes' conviction for tampering with electronic monitoring equipment and that cumulative error did not deny him a fair trial. View "State v. Barnes " on Justia Law

In 2016, Robert Edward Smith was involved in a home invasion that resulted in the murder of Donna O'Neal. Smith was charged with first-degree felony murder, aggravated burglary, attempted aggravated robbery, two counts of aggravated assault, and criminal possession of a weapon. The case was delayed due to extensive pretrial litigation and the COVID-19 pandemic, leading to a mistrial in July 2021. Smith's retrial began in May 2023, where he was ultimately convicted on all charges.The Sedgwick District Court initially handled the case, where Smith raised several issues, including a violation of his constitutional right to a speedy trial, prosecutorial error, and the right to present a defense. The district court denied Smith's motions, including his motion to dismiss based on the speedy trial claim and his objections to the State's mid-trial amendment of the information.The Kansas Supreme Court reviewed the case and addressed multiple issues. The court found that the 21.5-month delay between Smith's mistrial and retrial did not violate his right to a speedy trial, considering the complexity of the case and the impact of the COVID-19 pandemic. The court also found no prosecutorial error in the prosecutor's comments during closing arguments and no violation of Smith's right to present a defense regarding the exclusion of third-party evidence and a probation violation warrant.However, the court agreed with Smith that the district court erred in including his 2003 criminal threat conviction in his criminal history score, as the statute under which he was convicted had been declared unconstitutional in State v. Boettger. The Kansas Supreme Court affirmed Smith's convictions but vacated his sentence and remanded the case for resentencing without including the 2003 conviction in his criminal history score. View "State v. Smith " on Justia Law