Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's convictions of first-degree murder and other crimes, holding that an assumed error and a prosecutorial error occurred in the proceedings below, but those errors did not require a reversal of Defendant's convictions.After a jury trial, Defendant was found guilty of murder in the first degree, attempted murder in the first degree, conspiracy to commit murder in the first degree, criminal solicitation to commit murder in the first degree, and other crimes. Defendant received a hard twenty-five life sentence for the first-degree murder. The Supreme Court affirmed, holding (1) presuming that the trial court erred in admitting a certain exhibit, there was no reasonable probability that the admission of the exhibit affected the outcome of Defendant's trial; and (2) the prosecutor made improper statements during closing argument, but the prosecutorial error was individually and cumulatively harmless. View "State v. Brown" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to suppress evidence obtained during a search that led to the State charging Defendant with possession of drugs and drug paraphernalia with the intent to distribute, holding that the district court properly denied the suppression motion.This appeal arose after police officers detained Defendant while he sat in a minivan in an alleyway. Defendant filed a motion to suppress the evidence obtained during the search, arguing that the seizure of the minivan violated his constitutional rights. The district court concluded that the detention was reasonable and justified under the public safety exception to the warrant requirement. The court of appeals affirmed. The Supreme Court affirmed, holding that the seizure of the minivan was reasonable under the Fourth Amendment and section 15 of the Kansas Constitution Bill of Rights. View "State v. Bates" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant of violating the Kansas Offender Registration Act (KORA) by failing to register, holding that the Legislature's decision to make the crime of failure to register a strict liability felony did not violate Defendant's substantive due process rights.On appeal, Defendant argued that Kan. Stat. Ann. 21-5203(e) violated his substantive due process rights by making a KORA violation a strict liability crime. The court of appeals affirmed. The Supreme Court affirmed, holding that Defendant failed to show that section 21-5203(e)'s strict liability criminalization of KORA registration violations did not violate Defendant's substantive due process rights. View "State v. Genson" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's second pro se motion to correct an illegal sentence for offenses he committed in 1993, holding that the trial court correctly sentenced Appellant.The sentencing court in this case ordered a hard fifteen life sentence with lifetime parole for Appellant's conviction of first-degree murder and a consecutive ninety-seven-month term of imprisonment for an aggravated robbery conviction. In his second pro se motion to correct an illegal sentence Appellant sought correction of a supervision term that he argued was required for the aggravated robbery sentence. The district court summarily denied the motion. The Supreme Court affirmed, holding that, under Kan. Stat. Ann. 21-4720(b), when a defendant is sentenced for both off-grid and on-grid crimes, the sentencing court only has authority to impose the supervision period associated with the off-grid crime. View "State v. Collier" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the decision of the trial court judge dismissing this case with prejudice after suppressing evidence as a discovery sanction, holding that, under the circumstances, the district court did not abuse its discretion in dismissing the case with prejudice.Defendant was charged with drug-related offenses. The district court ultimately dismissed the charges with prejudice after suppressing certain evidence as a discovery sanction. The court of appeals reversed and remanded hte case, concluding that the district court abused its discretion by dismissing the case with prejudice for a discovery failure. The Supreme Court reversed, holding (1) the judge infringed on the prosecutor's discretion by not leaving to the prosecutor the decision of whether to proceed to trial; and (2) the error was harmless. View "State v. Mulleneaux" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of a panel of the court of appeals affirming Defendant's conviction of possession of more than 3.5 grams of methamphetamine with intent to distribute, possession of a firearm within ten years of a prior felony conviction, and two counts of drug paraphernalia possession, holding that insufficient evidence supported Defendant's firearm possession conviction.On appeal, Defendant raised six allegations of error. The Supreme Court reversed in part, holding (1) the panel erred when it refused to consider for the first time on appeal the legal appropriateness of an intent-to-distribute instruction and the instruction's permissive inference was legally inappropriate, but this error was not prejudicial; (2) Defendant's constitutional challenges failed; (3) there was insufficient evidence to support Defendant's firearm conviction; and (4) Defendant was not entitled to relief on his remaining claims of error. View "State v. Valdez" on Justia Law

The Supreme Court affirmed Defendant's convictions for two counts of first-degree premeditated murder, holding that any error in this case did not affect the verdict and was therefore harmless.On appeal, Defendant asserted multiple claims of trial error, including a claim that the district court clearly erred by failing to provide the jury with a cautionary instruction on the reliability of eyewitness identifications. The Supreme Court affirmed the convictions, holding (1) the district court erred by failing to provide the cautionary instruction, which was legally and factually appropriate, at trial, but the court's instructional error did not warrant reversal; and (2) Defendant's remaining claims of error were without merit. View "State v. Shields" on Justia Law

The Supreme Court affirmed Defendant's conviction for failing to register as a violent offender in Shawnee County in November 2017, holding that there was sufficient evidence to support the conviction.Defendant's obligation to register under the Kansas Offender Registration Act, Kan. Stat. Ann. 22-4902 et seq., arose after he was found guilty of robbery and criminal use of a financial card. After Defendant was released from prison, he failed to register in Shawnee County during November 2017. The State subsequently charged him with a registration violation under section 22-4905(b). A jury convicted Defendant of violating the registration requirements. Defendant appealed, arguing that the jury could not reasonably infer that he resided in Shawnee County in November 2017. The Supreme Court affirmed, holding that the evidence provided a basis for a reasonable inference that Defendant resided in Shawnee County in November 2017. View "State v. Huey" on Justia Law

In 2004, Ross was convicted of first-degree murder, attempted first-degree murder, and criminal possession of a firearm. He was sentenced to life imprisonment plus nine months (consecutive) for criminal possession of a firearm. The Kansas Supreme Court affirmed. Ross continued to seek relief through several post-conviction motions.In 2021, Ross filed a pro se motion captioned "Informational defect/Lack of Jurisdiction under K.S.A. 22-3201(b)(c)(e)(f)(g)(e)," arguing that the criminal complaint filed by the state "failed to confer subject matter jurisdiction on the trial court" because it failed to state essential facts constituting each of the charged offenses. The district court reviewed the claim on the merits but denied his request for relief: "Charging documents do not bestow or confer subject matter jurisdiction on state courts to adjudicate criminal cases; the Kansas Constitution does. … A charging document shall state "essential facts" constituting the crime charged, and the document "shall be deemed sufficient" if it is "drawn in the language of the statute." In Ross’s case, the charging document adequately stated the elements of the crimes of conviction. The Kansas Supreme Court affirmed. Ross failed to identify a timely, unexhausted, and proper procedural vehicle for presenting his subject matter jurisdiction challenge. View "State v. Ross" on Justia Law

Bailey was convicted of aggravated criminal sodomy in 1988 for his role in an incident in the Wyandotte County jail. Bailey's third petition for forensic DNA testing of biological material from a rape kit was summarily denied. He did not appeal one of the earlier denials but appealed the second and lost on appeal.The Kansas Supreme Court affirmed. Bailey is barred from relitigating the issues he raised by the application of issue preclusion principles to the prior determinations that he cannot meet the threshold requirements of K.S.A. 2020 Supp. 21-2512(a), which allows certain criminally convicted individuals to petition for postconviction forensic DNA testing. The prior rulings holding the state has no biological material related to Bailey's convictions in its actual or constructive possession is determinative of his ability to obtain postconviction forensic testing. View "State v. Bailey" on Justia Law