Justia Kansas Supreme Court Opinion Summaries

Appellant, a persistent sex offender involuntarily committed to Larned State Security Hospital, filed three petitions for writs of habeas corpus. Without requiring responses from the Secretary of the Kansas Department for Aging and Disability Services and without conducting hearings, the district court dismissed the petitions, concluding that Appellant’s failure to exhaust administrative remedies precluded habeas corpus relief. The court of appeals affirmed. The Supreme Court reversed, holding that the 2012 legislature expressly exempted habeas corpus proceedings from the exhaustion requirements of Kan. Stat. Ann. 59-29a24, and therefore, the district court erred in dismissing the petitions for failure to exhaust administrative remedies. View "Stanley v. Sullivan" on Justia Law

After a jury trial, Defendant was convicted of premeditated first-degree murder and aggravated burglary. Utilizing Kan. Stat. Ann. 21-4635, the sentencing judge imposed a sentence of life imprisonment without the possibility of parole for fifty years for Defendant’s murder conviction. Defendant appealed, arguing, among other things, that the sentencing judge erred in imposing a hard fifty sentence because section 21-4635, the hard sentencing statute in effect at the time of his sentencing, was unconstitutional. The Supreme Court affirmed Defendant’s convictions, vacated his hard fifty sentence, and remanded for resentencing, holding that section 21-4635 violates the Sixth Amendment because it imposes additional punishment based on factors not submitted to a jury and proven beyond a reasonable doubt. View "State v. Holt" on Justia Law

After a jury trial, Defendant was convicted of premeditated first-degree murder and two counts of aggravated assault. The district court found aggravating circumstances to impose a hard fifty life sentence on Defendant’s first-degree murder conviction. The Supreme Court affirmed the convictions but vacated Defendant’s sentence, holding (1) certain statements made by the prosecutor, although arguably misconduct, were very mild and made in response to defense counsel’s argument; (2) any error in failing to provide a second-degree murder instruction was harmless beyond a reasonable doubt; (3) cumulative error did not deny Defendant a fair trial; and (4) in accordance with State v. Soto, Defendant’s hard fifty sentence was unconstitutionally imposed by the district court in violation of Defendant’s Sixth Amendment right to a jury trial. Remanded for resentencing. View "State v. Roeder" on Justia Law

After a jury trial, Defendant was convicted of voluntary manslaughter and sentenced to 216 months’ imprisonment. The court of appeals affirmed on direct appeal. Defendant subsequently filed the present pro se motion for postconviction relief under Kan. Stat. Ann. 60-1507, alleging that his trial counsel was ineffective in three distinct ways. The district court denied the motion. The court of appeals affirmed. The Supreme Court reversed, holding that the district court erred by denying Defendant’s 60-1507 motion without an evidentiary hearing, as the motion, files, and records failed to show conclusively that Defendant was not entitled to relief. Remanded for an evidentiary hearing regarding Defendant’s allegations. View "Sola-Morales v. State" on Justia Law

The Attorney General alleged that the Chief Judge of the Tenth Judicial District exceeded his authority and contravened Kansas law by issuing an administrative order permitting marriage licenses to be issued to same sex couples. The Attorney General sought an order directing the Chief Judge and clerk of the district court to immediately cease from issuing marriage applications or licenses to same gender couples and an order vacating the Judge’s administrative order. The Supreme Court declined to grant the relief sought, as the Attorney General's right to relief on the merits was not clear, but granted the Attorney General’s alternative request for a temporary stay of the Chief Judge’s administrative order insofar as the order allows issuance of marriage licenses. The Court then requested additional briefing on the pending issues of whether the Chief Judge possessed authority to issue the administrative order and whether the interpretations and applications of the United States Constitution by the Tenth Circuit Court of Appeals are supreme and modify any Kansas state ban on same-sex marriage. View "State v. Moriarty" on Justia Law

After a jury trial, Defendant was convicted of attempted aggravated interference with parental custody and disorderly conduct. The court of appeals found several trial errors, including two instances of prosecutorial misconduct and three jury instruction errors, but concluded that the errors did not deprive Defendant of a fair trial. The Supreme Court reversed Defendant’s conviction for attempted aggravated interference with parental custody and affirmed her conviction for disorderly conduct, holding (1) two of the trial errors, both of which related to Defendant’s defense of ignorance or mistake, warranted the reversal of Defendant’s conviction for attempted aggravated interference with parental custody; and (2) the prejudice Defendant suffered as a result of these errors did not taint her conviction for disorderly conduct, nor did any other claimed errors. View "State v. Ortega" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, aggravated kidnapping, and aggravated robbery. After the sentencing judge found by a preponderance of the evidence the existence of four aggravating factors, Defendant received a hard fifty life sentence for the first-degree murder conviction. Defendant appealed, raising nine issues challenging his convictions and two challenging his sentences. The Supreme Court (1) affirmed Defendant’s convictions, thus rejecting Defendant’s claims of reversible error; and (2) vacated Defendant’s sentence for first-degree murder, holding that Defendant’s Sixth Amendment right to a jury trial, as interpreted in Alleyne v. United States, was violated because the judge, rather than the jury, found the four aggravating factors existed and did so on a preponderance-of-the-evidence standard, rather than a beyond-a-reasonable-doubt standard.View "State v. Hilt" on Justia Law

After a jury trial, Defendant was convicted of aggravated indecent liberties with a child. The Supreme Court reversed in part, holding that the trial court denied Defendant his right under the Sixth Amendment to have the effective assistance of counsel at a critical stage of the criminal proceedings against him when the court denied Defendant’s pro se motions for a new trial without first appointing new conflict-free counsel to assist Defendant in arguing the motions. Remanded for appointment of new counsel and instructions to hold a new holding on Defendant’s pro se motions for new trial.View "State v. Sharkey" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to life imprisonment without the possibility of parole for fifty years. The Supreme Court affirmed Defendant’s conviction but vacated his sentence, holding that Kansas’ hard fifty sentencing scheme violates the Sixth Amendment to the federal Constitution as interpreted in Alleyne v. United States and Ring v. Arizona because it permits a judge to find by a preponderance of the evidence the existence of one or more aggravating factors necessary to impose an increased mandatory minimum sentence, rather than requiring a jury to find the existence of the aggravating circumstances beyond a reasonable doubt. Remanded for resentencing.View "State v. Soto" on Justia Law

The State charged Defendant with possession of methamphetamine after law enforcement officers stopped Defendant’s vehicle based on a turn signal violation, searched the vehicle because they detected a very strong odor of alcohol coming from within the vehicle, and discovered methamphetamine during the search. Defendant filed a motion to suppress the fruits of the warrantless search. The district court denied the motion, concluding that the strong odor of alcohol emanating from within the vehicle established probable cause for the officers to search the vehicle for an open container of alcohol. The Supreme Court reversed, holding that the search was unlawful because the officers failed to acquire additional inculpatory facts relating to the crime being investigated before commencing their search of the vehicle.View "State v. Stevenson" on Justia Law