Justia Kansas Supreme Court Opinion Summaries

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

After a bench trial, Defendant was convicted of felony murder and aggravated robbery. The Supreme Court affirmed the convictions, holding (1) there was sufficient evidence to convict Defendant of both felony murder and aggravated robbery; (2) Defendant knowingly and voluntarily waived his right to a jury trial; and (3) the district court did not err in denying Defendant’s motion to dismiss the charges against him based on the State’s alleged destruction of certain evidence. However, because the district court erred in imposing lifetime parole in connection with Defendant’s aggravated robbery conviction, the Court vacated that portion of Defendant’s sentence and remanded for resentencing. View "State v. Lewis" on Justia Law

After a jury trial, Defendant was convicted of premeditated first-degree murder and criminal discharge of a firearm at an occupied building. The Supreme Court affirmed Defendant’s convictions and sentences, holding (1) the trial court did not err in admitting Defendant’s statements to law enforcement officers, as the confession was not involuntary and Defendant was not denied his right to counsel during the interrogation; (2) the trial court did not err by admitting into evidence certain hearsay statements; (3) the trial court did not commit clear error when it failed sua sponte to give an instruction on eyewitness testimony; (4) there was sufficient evidence to support Defendant’s conviction for premeditated first-degree murder; and (5) Defendant failed to establish that his counsel provided ineffective assistance. View "State v. Betancourt" on Justia Law

A law enforcement officer, while working on a saturation patrol, stopped a vehicle driven by Defendant and conducted a DUI investigation. Defendant failed the horizontal gaze nystagmus (HGN) test but passed the walk-and-turn and one-leg-stand tests. The officer subsequently requested a preliminary breath test (PBT), the results of which led to Defendant’s arrest and conviction for DUI. Defendant moved to suppress the PBT and breath test results. At the suppression hearing, the district court found that although an HGN test result was inadmissible at trial, it could be used to support “probable cause,” and, under the totality of the circumstances, there was reasonable suspicion to request the PBT. The Court of Appeals affirmed, concluding (1) the HGN test could be used to establish reasonable suspicion of DUI that would permit a request for a PBT; and (2) even if the HGN test results were excluded, the officer had enough other evidence to form a reasonable suspicion of DUI. The Supreme Court reversed, holding that the HGN test results were inappropriately relied upon to establish the requisite reasonable suspicion that permitted the officer to request that Defendant submit to a PBT, and the error was not harmless. Remanded. View "City of Wichita v. Molitor" on Justia Law

After a jury trial, Defendant was found guilty of premeditated first-degree murder and sentenced to life in prison without the possibility of parole for fifty years. The Supreme Court affirmed Defendant’s conviction, holding (1) the district court applied the wrong legal standard when it denied Defendant’s request for a jury instruction on second-degree intentional murder, but the error was harmless; (2) the prosecutor made an improper comment during closing argument, but the comment did not constitute reversible error; and (3) the remaining alleged trial errors raised on appeal were without merit. The Court vacated Defendant’s sentence, however, holding that the district court violated Defendant’s Sixth Amendment right to a jury trial based on Alleyne v. United States because the court made explicit factual findings that subjected Defendant to an enhanced sentence. View "State v. Killings" on Justia Law

After a jury trial, Defendant was convicted for distribution of methamphetamine, unlawful use of a communication facility to arrange a drug sale, and fleeing or attempting to elude a police officer, among other crimes. The Supreme Court affirmed Defendant’s convictions and sentence, holding (1) the State established that venue to prosecute the use of a communication facility charge was proper in Lyon County; (2) the district court did not err in failing to instruct on underlying moving violations supporting the fleeing or attempting to elude a police officer charge; (3) the district court did not err in failing to give a unanimity instruction on the obstruction of official duty charge; (4) the State presented sufficient evidence to convict Defendant of the distribution of methamphetamine charge; and (5) the imposition of an enhanced sentence was proper. View "State v. Castleberry" on Justia Law

Defendant was convicted in two separate trials of first-degree premeditated murder in the death of Alfred Mack, second-degree intentional murder in the later death of Justin Letourneau, theft, and aggravated assault. Defendant appealed, raising several allegations of error. The Supreme Court reversed all of Defendant’s convictions under the cumulative error doctrine, holding (1) the district judge erred in excluding testimony about a statement Letourneau made in the hours before his death; (2) the jury instruction on alternative first-degree murder theories contained a misstatement of law with respect to reasonable doubt; (3) the district judge erred by not instructing the jury to begin its deliberations anew after one juror had been dismissed and replaced by an alternative juror; and (4) the district judge’s failure to recall some members of the jury when one juror raised the issue of jury misconduct after trial. View "State v. Smith-Parker" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder. The district court sentenced Defendant to a hard fifty sentence, which was imposed under Kan. Stat. Ann. 21-4635. The Supreme Court affirmed, holding (1) Defendant’s trial counsel did not provide ineffective assistance; (2) the district court did not err by admitting testimony concerning a confrontation between Defendant and the victim a few days before the murder, as the testimony was admissible under a hearsay exception to the general exclusionary rule; (3) the prosecutor did not engage in misconduct; but (4) because section 21-4635 has been found unconstitutional, Defendant’s hard fifty sentence was vacated and the case remanded to the district court for resentencing. View "State v. Coones" on Justia Law

Appellant pleaded no contest to premeditated first-degree murder, aggravated robbery, and forgery and was sentenced to life in prison, with no parole eligibility for twenty-five years. Nearly eleven years after her sentencing, Appellant filed a motion to withdraw her pleas because of manifest injustice, arguing that her lawyer misinformed her about the charges and possible penalties and that she did not understand the length of the prison sentence to which she could be subject if she entered the pleas. The district court denied the motion. The Supreme Court affirmed, holding that even if Appellant’s attorney misinformed or failed to fully inform Appellant of the charges and possible penalties, any prejudice from that error was cured by the judge’s thoroughness at the plea hearing. View "State v. Miles" on Justia Law