Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction for premeditated first-degree murder, along with his hard fifty sentence, holding that there was no reversible error.Specifically, the Supreme Court held (1) the district court did not err by telling the venire that the trial was "not a capital punishment case"; (2) the jury instruction on aiding and abetting was both legally and factually appropriate, and therefore, there was no error in submitting this instruction to the jury; (3) the prosecutor committed error in several portions of closing arguments, but the errors did not require reversal, either individually or cumulatively; and (4) the district court did not abuse its discretion by refusing to depart from the presumptive hard fifty sentence. View "State v. Blevins" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the ruling of the district court granting Defendant's motion to suppress the fruits of a vehicle search conducted by the Kansas Highway Patrol, holding that the suppression motion was improperly granted.The vehicle search in this case was based on a drug dog alert that occurred following a highway patrol trooper's processing of Defendant's traffic offense. The district court concluded that the duration of Defendant's detention to await the drug dog was unlawful and excessive. The court of appeals affirmed. The Supreme Court reversed, holding (1) the trooper acted diligently under the circumstances; and (2) the continued detention was not excessive or unlawful. View "State v. Arrizabalaga" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's request for relief under Kan. Stat. Ann. 21-6628(c), formerly Kan. Stat. Ann,. 21-4639, holding that the district court properly denied Defendant's motion for sentence modification.Appellant was convicted of first-degree premeditated murder and sentenced to a hard fifty life sentence. Appellant later brought this action asserting that he must be resentenced under section 21-6628 because the rule announced in Alleyne v. United States, 570 U.S. 99 (2013), rendered unconstitutional the sentencing statutes under which he was sentenced. The district court denied relief. The Supreme Court affirmed, holding that there was no procedural mechanism by which a Kansas court may reconsider Defendant's sentence. View "State v. Johnson" on Justia Law

The Supreme Court affirmed Defendant's conviction on multiple drug charges, holding that the district court did not err in denying Defendant's motion to suppress drug evidence seized during a traffic stop.At issue on appeal was whether the arresting officer had the requisite reasonable suspicion to extend the traffic stop to ask questions about two items that were hanging out of a partially opened safe on the rear floorboard of the vehicle Defendant was driving. In denying Defendant's motion to suppress the district court found that the officer had reasonable suspicion to extend the traffic stop. The court of appeals affirmed. The Supreme Court affirmed, holding that, viewing the totality of the circumstances, the court of appeals properly concluded that the law enforcement officers had reasonable suspicion that criminal activity was afoot. View "State v. Cash" on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendant's motion to withdraw his guilty plea to first-degree murder, holding that the district court did not abuse its discretion when it found that Defendant failed to establish good cause and denied his motion to withdraw plea.In his motion to withdraw his plea, Defendant argued that his counsel was ineffective for failing to investigate a voluntary intoxication theory of defense because Defendant had told counsel that he was on antidepressants at the time of the murder. The trial court denied the motion, finding counsel's investigation of Defendant's medication legally sufficient to support a finding of competent representation. The Supreme Court affirmed, holding that the district court did not abuse its discretion. View "State v. Barber" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that no exceptions extended the statutory speedy trial period in this case and that Defendant must be discharged from liability on the charges against him, holding that the State violated Defendant's statutory speedy trial rights.Defendant was charged with premeditated first-degree murder and two counts of attempted first-degree murder. The State did not bring Defendant to trial until 153 days after his arraignment. After he was convicted, Defendant appealed, arguing that the State violated his statutory right to a speedy trial. The Supreme Court agreed and reversed Defendant's convictions, holding that, under Kan. Stat. Ann. 22-3402(a), Defendant's right to a speedy trial was violated. View "State v. Queen" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Richard Quillen's petition to be placed in transitional release from his civil commitment as a sexually violent predator under the Kansas Sexually Violent Predator Act (KSVPA), holding that the jury instructions given at Quillen's transitional release hearing were constitutionally adequate.After a jury trial, the court found that Quillen's mental abnormality or personality disorder remainder such that he was not safe to be placed in transitional release. On appeal, Quillen argued that the district court erred when it denied his request for an instruction that the jury must find Quillen had serious difficulty controlling his behavior. The Supreme Court affirmed, holding (1) at a transitional release hearing, substantive due process requirements are satisfied when the jury instructions as a whole require the jury to necessarily and implicitly find the respondent continues to have serious difficulty controlling his dangerous behavior; and (2) the jury instructions in Quillen's case were constitutionally adequate under this standard. View "In re Care & Treatment of Quillen" on Justia Law

The Supreme Court affirmed the judgment of the district court reversing Defendant's conviction of aggravated battery, rape, and aggravated kidnapping on the grounds that a conflict of interest existed between Defendant and his counsel that adversely affected the representation.In his Kan. Stat. Ann. 60-1507 motion for relief from his convictions Defendant argued that his counsel had a personal and financial conflict of interest that adversely affected his performance in Defendant's case. The district court agreed and set aside Defendant's convictions without determining whether prejudice resulted from the conflict of interest. The Supreme Court affirmed, holding that Defendant's convictions must be reversed based on the financial conflict of interest of his trial counsel. View "Ellie v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for possession of marijuana, methamphetamine, and drug paraphernalia, holding that the trial court erred in admitting evidence that a syringe was found by police during a search that violated Defendant's Fourth Amendment rights but that the error was harmless.On appeal, the State conceded that the district court should have granted Defendant's motion to suppress on the syringe, admitting that the search incident to arrest exception for a warrantless search did not apply to this particular search. The court of appeals affirmed, accepting the State's concession that the syringe discovery was the product of an illegal search but without determining whether the evidence was harmless beyond a reasonable doubt. The Supreme Court affirmed, holding the court's admission of the syringe evidence was harmless beyond a reasonable doubt. View "State v. Thornton" on Justia Law

The Supreme Court reversed Defendant's conviction for distribution of a controlled substance and affirmed Defendant's remaining convictions, holding that there was insufficient evidence to support the distribution conviction.A jury found Defendant guilty of felony murder, distribution of a controlled substance, attempted aggravated robbery, criminal possession of a weapon, attempted murder in the second degree, criminal discharge of a firearm, aggravated battery, and aggravated burglary. The Supreme Court reversed one conviction and otherwise affirmed, holding (1) the district court did not abuse its discretion in consolidating Defendant's cases for trial; (2) the evidence was insufficient to convict Defendant of distribution; and (3) the jury instructions on Defendant's aggravated robbery, felony murder, and criminal possession of a firearm charges were not erroneous. View "State v. Crosby" on Justia Law