Justia Kansas Supreme Court Opinion Summaries

In 2010, Plaintiffs filed an action claiming that the State violated Kan. Const. art. VI, 6(b) by inequitably and inadequately funding K-12 public education. A three-judge panel determined that, through the School District Finance and Quality Performance Act (SDFQPA), the State had inequitably and inadequately funded education in violation of Article 6. On appeal, the Supreme Court affirmed the panel on equity but determined that the panel did not apply the correct standard in concluding that the State violated the adequacy component. On remand, the panel declared the financing under the SDFQPA and the subsequently enacted Classroom Learning Assuring Student Success Act (CLASS), which replaced the SDFQPA, to be constitutionally inadequate. The Supreme Court affirmed, holding that the panel correctly found that the financing system is constitutionally inadequate. As a remedy, the Court stayed the issuance of today’s mandate and ordered that, by June 30, 2017, the State must demonstrate that any K-12 public education financing system the legislature enacts is capable of meeting the adequacy requirements of Article 6. Otherwise, a lifting of the stay of today’s mandate will mean that the State’s education financing system is constitutionally invalid and therefore void. View "Gannon v. State" on Justia Law

The one-subject rule in Article 2, Section 16 of the Kansas Constitution provides that “[n]o bill shall contain more than one subject, except appropriation bills an bills for revision or codification of statutes.” At issue in this case was whether 2014 Senate Substitute for House Bill No. 2506 violates the one-subject rule. Kansas National Education Association (KNEA) argued that the bill violates the one-subject rule because it contains both appropriations and substantive general legislation. The district court dismissed the complaint, concluding that KNEA failed to state a claim as a matter of law because H.B. 2506 did not violate Article 2, Section 16. The Supreme Court affirmed, holding (1) KNEA had standing to bring this lawsuit, and its claim is ripe; (2) Article 2, Section 16 does not forbid combining appropriations and general legislation into one bill, provided that all provisions of that bill address the same subject; and (3) H.B. 2506’s provisions relate to one subject. View "Kansas National Education Ass’n v. State" on Justia Law

Defendant was charged with possession of methamphetamine after the vehicle in which he was a passenger was detained for a traffic stop and a law enforcement officer conducted searches of Defendant and his effects, including a cigarette package in which methamphetamine was found. Defendant filed a motion to suppress, arguing that the evidence was obtained during an unlawful warrantless search. The district court denied the motion. The Court of Appeals affirmed, concluding that the final search of the cigarette package was consensual and sufficiently attenuated from an earlier unlawful pat-down of Defendant. The Supreme Court reversed, holding (1) under the totality of the circumstances of this case, the nature of Defendant’s unlawful seizure rendered his consent to the search of the cigarette package involuntary and, therefore, invalid; and (2) therefore, the district court erred in refusing to suppress the evidence seized from the cigarette package. View "State v. Cleverly" on Justia Law

The State sought to have Todd Ellison, a convicted sex offender, involuntarily committed under the Kansas Sexually Violent Predator Act. Under the Act, Ellison was entitled to a jury trial during which the State must prove its case beyond a reasonable doubt. Ellison, however, waited in jail for more than four years without a trial. The district court concluded that the delay violated Ellison’s due process rights, dismissed the action, and ordered Ellison released. A court of appeals panel reversed and remanded the case for further proceedings to more fully address the due process issue. The Supreme Court reversed the court of appeals and affirmed the order of release, holding (1) the district court did not err when it applied Barker v. Wingo to Ellison’s due process claim; and (2) the court of appeals panel erred when it concluded that the district court failed to render adequate factual findings and incorrectly based its release order solely on the length of delay. View "In re Care & Treatment of Ellison" on Justia Law

After a jury trial, Defendant was convicted of identity theft and felony theft. Defendant appealed, arguing, in part, that the district court judge erred in denying Defendant’s motion to suppress evidence obtained from a law enforcement car stop. The court of appeals affirmed, holding that a suspicious character tip such as that motivating the car stop at issue was not enough to support reasonable suspicion of a crime, but reasonable suspicion nonetheless existed. The Supreme Court affirmed, holding that there was no reasonable suspicion of criminal activity to support the stop of the car Defendant was driving, and therefore, Defendant’s motion to suppress should have been granted. View "State v. Chapman" on Justia Law

Defendant was convicted of driving under the influence. Defendant appealed, arguing, among other things, that the district court erred by not granting his motion to suppress evidence of his blood alcohol content obtained from a breath test. Specifically, Defendant alleged that he had been unconstitutionally coerced into submitting to the test because officers threatened to obtain a warrant for a blood test when the officers could have lawfully obtained the warrant. The court of appeals affirmed. The Supreme Court affirmed, holding that Kansas law permits law enforcement officers to to obtain a warrant for a blood draw after a breath test refusal, and therefore, the threat to do so was not coercive. View "City of Dodge City v. Webb" on Justia Law

After a jury trial, Defendant was convicted of capital murder, aggravated burglary, and attempted rape. The district court imposed the death sentence for the capital murder conviction and time in prison for the remaining convictions. The Supreme Court remanded after finding reversible error relating to Defendant’s capital sentence. After a new sentencing proceeding, the district court imposed the death sentence for the capital murder conviction and prison sentences for the remaining convictions. Defendant appealed, raising several allegations of error. The Supreme Court affirmed Defendant’s capital murder conviction and his death sentence but reversed Defendant’s attempted rape conviction as multiplicitous, vacated his sentence for attempted rape, and remanded for resentencing on the other conviction of aggravated burglary, holding that an intervening change in the law required reversal of Defendant’s attempted rape conviction. View "State v. Kleypas" on Justia Law

After a jury trial, Defendant was convicted of premeditated first-degree murder. Defendant appealed, raising several claims of error, including claims of prosecutorial misconduct. The Supreme Court affirmed, holding (1) the State demonstrated beyond a reasonable doubt that a single error on the part of the prosecutor did not affect the outcome of the trial, and Defendant’s remaining prosecutorial misconduct claims were without merit; (2) Defendant did not meet the clear error standard for reversal based on the district judge’s early mistake in making statements to potential jurors before voir dire; (3) the district judge erred in omitting an instruction on reckless second-degree murder, but the jury would not have reached a different verdict had the instruction been given; and (4) cumulative error did not necessitate reversal. View "State v. Carter" on Justia Law

Defendant was charged with felony driving under the influence as a three-time offender, refusing a preliminary breath test, and transporting an open container. Defendant filed a motion to suppress evidence obtained when police officers entered his home without a search warrant. The district court judge denied the motion. The Court of Appeals affirmed. The Supreme Court affirmed, although its reasoning differed from that of the district judge and the Court of Appeals, holding (1) the officers had probable cause to arrest Defendant for driving under the influence before they entered his home; and (2) even if there was error, the error was not reversible. View "State v. Keenan" on Justia Law

Defendant was convicted of first-degree murder and aggravated burglary. The trial court sentenced Defendant to a hard twenty-five life sentence for the first-degree murder conviction. The Supreme Court affirmed, holding (1) the district court did not err in failing to instruct the jury on voluntary manslaughter, unintentional second-degree murder, and reckless involuntary manslaughter; (2) the district court did not err by excluding evidence that the shooting happened in a high crime area; (3) the district court did not err in denying Defendant’s request for a trial continuance; (4) the district court did not err in denying Defendant’s motion for new trial based on ineffective assistance of counsel; and (5) cumulative error did not deprive Defendant of a fair trial. View "State v. Johnson" on Justia Law