Justia Kansas Supreme Court Opinion Summaries

Law enforcement officers employed by the City of Prairie Village set up a controlled drug buy from Defendant to occur in the City of Leawood. As a result of the controlled buy, the State charged Defendant with felony drug charges. Defendant moved to suppress the drugs and an audio recording of the controlled buy, arguing that the Prairie Village officers had obtained that evidence while exercising their police powers outside of their jurisdiction as authorized under Kan. Stat. Ann. 22-2401(a)(2). The district court granted the motion and suppressed the evidence. The court of appeals reversed, finding that the Prairie Village officers had jurisdiction in Leawood based on a provision in section 22-2401(a)(2)(b) allowing municipal officers to exceed their jurisdictional boundaries when another jurisdiction requests assistance. The Supreme Court affirmed on different grounds, holding (1) the statutory limitations on the jurisdiction of city officers was put in place to protect the local autonomy of neighboring cities and counties, rather than to create an individual right; and (2) consequently, the suppression of any evidence obtained during a city officer’s unauthorized exercise of police power outside the officer’s employing city will generally not be required. View "State v. Vrabel" on Justia Law

After a jury trial, Defendant was convicted of six drug offenses. The court of appeals affirmed in part and reversed in part, resulting in a reversal of one of Defendant’s convictions and the vacating of one of his sentences. Those issues were not before the Supreme Court for review. On appeal, Defendant sought the Court’s review of that portion of the court of appeals’ decision that was adverse to him. The Supreme Court affirmed, holding that the district court did not err in (1) denying Defendant’s motion to suppress evidence obtained from the warrantless search of his vehicle; (2) convicting Defendant for the separate offenses of possessing red phosphorous and iodine and possessing drug paraphernalia with intent to manufacture, as those convictions were not multiplicitous; and (3) using Defendant’s prior convictions to enhance his sentence. View "State v. Overman" on Justia Law

While fleeing the police during a high-speed chase, Defendant collided with another vehicle, killing both occupants. After a jury trial, Defendant was convicted of two counts of first-degree felony murder and one count of fleeing or attempting to elude a police officer. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by urging defense counsel to complete voir dire or setting a time limitation on the second day; (2) the district court’s remark in the jury’s presence about the time defense counsel was taking during voir dire was not improper or prejudicial; (3) the district court did not err in refusing to change venue; (4) the prosecutor made a misstatement as to the process for considering lesser included offenses, but the misstatement did not so prejudice the jury as to deny Defendant a fair trial; and (5) the State properly charged felony murder rather than involuntary manslaughter while driving under the influence. View "State v. Hudgins" on Justia Law

Defendant pled guilty to one count of first-degree murder. Just over one year later, the clerk of the district court received a pro se motion for postconviction relief pursuant to Kan. Stat. Ann. 60-1507, in which Defendant alleged that he received ineffective assistance of counsel. Defendant filed his supporting memorandum less than one month later. The district court summarily denied the motion, concluding that Defendant had waived his right to file a section 60-1507 motion based on the purported ineffective assistance of counsel and that the motion was time-barred. The Court of Appeals affirmed but on different grounds, concluding that Defendant’s supporting memorandum should be treated as an attempted section 60-1507 amendment and that the amendment was time-barred. The Supreme Court reversed, holding (1) the district court erred by concluding that Defendant waived his right to file a section 60-1507 motion alleging ineffective assistance of counsel; (2) the district court erred by concluding that Defendant failed to file his section 60-1507 motion within the one-year time limitation in Kan. Stat. Ann. 60-1507(f)(1); and (3) the Court of Appeals erred in affirming the district court’s dismissal after treating the supporting memorandum as an untimely amendment. Remanded. View "Wahl v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder and arson. The district court imposed a hard fifty life sentence after finding that Defendant committed the murder in an especially heinous, atrocious, or cruel manner. The Supreme Court affirmed the convictions but vacated the sentence and remanded for resentencing, holding (1) the district court did not err in denying Defendant’s request for a jury instruction on self-defense; (2) any error in denying Defendant’s request for a voluntary manslaughter instruction based on a theory of imperfect self-defense was harmless; (3) the district court erred in admitting Defendant’s recorded confession when Defendant unambiguously invoked his right to have counsel present during custodial interrogation, but the error was harmless; and (4) Defendant’s hard fifty sentence was unconstitutional under Alleyne v. United States because the district court denied Defendant the right to have a jury decide beyond a reasonable doubt all of the facts that may increase the penalty for first-degree murder. View "State v. Salary" on Justia Law

After a jury trial, Defendant was found guilty of felony murder and criminal discharge of a firearm at an occupied building. During trial, the jury received instructions on second-degree unintentional murder and involuntary manslaughter as lesser included offenses of felony murder. Defendant appealed, arguing that the prosecutor misstated the law - thus, committing misconduct - when he told the jurors during closing arguments that they were to consider Defendant’s guilt for the lesser included crimes only after finding him not guilty of felony murder. The Supreme Court affirmed, holding (1) the prosecutor’s statement was erroneous because it suggested to the jury that it must unanimously acquit him of felony murder before considering his guilt for the lesser included crimes; but (2) because the prosecutor also recited the correct legal standard during closing arguments and the overwhelming evidence established Defendant’s guilt for felony murder, the prosecutor’s erroneous statement did not constitute reversible misconduct. View "State v. Parker" on Justia Law

After a jury trial, Defendant was convicted of capital murder, vehicle burglary, and theft. The Supreme Court affirmed, holding (1) the trial court did not err when it denied Defendant’s motion for change of venue; (2) even if the trial court erred in failing to instruct on the lesser included offense of felony murder, Defendant was not entitled to the requested relief of a new trial during which the jury would receive a felony-murder instruction; (3) any error in failing to instruct on the lesser included offense of reckless second-degree murder was harmless; (4) the trial court did not err in admitting a before-death photograph of the victim; (5) the trial court did not rule unreasonably in admitting a video of Defendant’s arrest; (6) the prosecutor did not commit misconduct during closing arguments; (7) the trial court did not err in failing to declare a mistrial; and (8) sufficient evidence supported the conviction for capital murder. View "State v. Longoria" on Justia Law

Defendant was visiting the home of a long-time acquaintance when police officers arrived. One of the officers walked to the backyard of the property and found a baggie of methamphetamine on the ground. Defendant was arrested and transported to jail, where officials discovered a baggie of marijuana during an inventory search of Defendant's belongings. Defendant was charged with several drug-related crimes. The district court granted Defendant’s motion to suppress, concluding that the methamphetamine was found in the curtilage of the home, that a social guest such as Defendant has standing to assert a host’s Fourth Amendment rights in the curtilage, and that marijuana found on Defendant was fruit of the poisonous tree. The Court of Appeals reversed. The Supreme Court reversed the Court of Appeals and affirmed the district court, holding (1) the Court of Appeals erred in reversing because the district court’s findings that the backyard was curtilage were supported by substantial competent evidence, and case law supported its legal conclusion that the area was curtilage; (2) a social guest has standing to challenge a search of the curtilage of the host’s residence; and (3) the marijuana should be suppressed as fruit of the poisonous tree. View "State v. Talkington" on Justia Law

Defendant pleaded guilty to aggravated arson, premeditated first-degree murder, and capital murder. The convictions stemmed from Defendant’s act of setting fire to a residence, which killed two people. Defendant was sentenced to two consecutive hard forty life sentences for the murders. Defendant later filed a pro se motion to correct an illegal sentence, arguing that the convictions were multiplicitous. The district court summarily dismissed the claim, concluding that the capital murder conviction would render moot any resentencing. The Supreme Court affirmed, albeit on different grounds, holding (1) Defendant’s multiplicity argument failed because multiplicity cannot be raised in a motion to correct an illegal sentence; and (2) Defendant’s contention that his sentence was unconstitutional similarly failed. View "State v. Noyce" on Justia Law

Petitioners were residents of a state hospital and involuntary participants in the Kansas Sexual Predator Treatment program at the hospital. Petitioners filed petitions for habeas corpus relief challenging the Program’s implementation of a new administrative grievance procedure. The district court summarily denied the petitions and assessed the costs of filing the action against each petitioner. The Court of Appeals affirmed the dismissal of the petitions but reversed the assignment of costs to Petitioners. The Supreme Court affirmed, holding that, whenever a person civilly committed files a habeas petition relating to his or her commitment, the costs shall be assessed to the counties in which the petitioners were determined to be sexually violent predators. View "Merryfield v. Sullivan" on Justia Law