Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's convictions for felony murder, criminal discharge of a firearm at an occupied vehicle, and aggravated assault, holding that there was no reversible error in the proceedings below.At his first trial, Defendant was convicted of criminal discharge of a firearm at a vehicle and aggravated assault, but the jury deadlocked on Defendant's felony-murder charge. After a second trial on the remaining charge, Defendant was convicted of felony murder. The Supreme Court affirmed, holding (1) the district court properly instructed the second jury on felony murder; (2) the State committed prosecutorial error in the first trial when it improperly appealed to the passions of the community, but the district court's prompt instruction to disregard cured this error, and any other assumed prosecutorial error was harmless; (3) the district court did not err in either trial by failing to instruct the jury on the lesser included offense of discharge of a firearm from a roadway; (4) there was no error in the jury instructions; and (5) the cumulative effect of any error was harmless. View "State v. Rhoiney" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for first-degree felony murder, holding that Defendant's arguments on appeal were unavailing.Defendant was convicted of first-degree felony murder, criminal threat, and distribution of methamphetamine. On appeal, Defendant argued that insufficient evidence supported his felony murder conviction and that the district court violated his common-law right to a jury trial by making judicial findings of his prior convictions to establish his sentence. The Supreme Court affirmed, holding (1) the evidence was sufficient to establish beyond a reasonable doubt that Defendant was guilty of felony murder; and (2) Defendant's constitutional challenge to the Kansas Sentencing Guidelines Act failed. View "State v. Pearce" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the decision of the district court dismissing as untimely and successive Defendant's motion filed under Kan. Stat. Ann. 60-1507, holding that the court was correct to dismiss the motion as untimely.Defendant was convicted in 2000 of premeditated murder, aggravated robbery, and aggravated burglary for acts he committed when he was fourteen years old. The district court sentenced Defendant to two concurrent life sentences without the possibility of parole for fifty years. Defendant later filed his section 60-1507 motion, arguing that the scheme under which he was sentenced violated the Eighth Amendment. The district court dismissed the motion. The court of appeals reversed, concluding that Defendant's motion was subject to an exception to the prohibition on successive motions. The Supreme Court reversed, holding that Defendant's sentencing scheme satisfied the constitutional requirements of Miller v. Alabama, 567 U.S. 460 (2012), and therefore, it was unnecessary to consider Defendant's motion to prevent manifest injustice. View "Williams v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of identity theft, holding that the State presented sufficient evidence to establish venue in Johnson County and that Defendant was properly convicted.In this ticket caper, a jury convicted Defendant of identity theft. On appeal, Defendant argued that there was insufficient evidence to establish that she used stolen information in Johnson County, and therefore, venue was improper, and that she was improperly convicted of identity theft. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to establish venue in Johnson County; and (2) because the elements of identity theft and criminal use of a financial card are different, the two statues do not present identical offenses, and the court of appeals did not err when it found the more specific statute rule did not apply. View "State v. Euler" on Justia Law

The Supreme Court affirmed Defendant's sentence of life imprisonment with no chance of parole for fifty years but vacated the district court's order imposing lifetime postrelease supervision and electronic monitoring as a condition of parole, holding that those components of Defendant's sentence were illegal.Defendant pleaded no contest to premeditated first-degree murder. The district court denied Defendant's request to depart from his presumptive hard fifty sentence and to instead sentence him to a hard twenty-five sentence. The court then imposed lifetime postrelease supervision and electronic monitoring as a condition of his parole. The Supreme Court affirmed Defendant's hard fifty sentence, holding that the district court (1) did not err in denying Defendant's departure motion; but (2) lacked authority to impose lifetime postrelease or electronic monitoring parole conditions. View "State v. Boswell" on Justia Law

The Supreme Court reversed the district court's ruling to strike Defendant's prior Missouri driving while intoxicated (DWI) convictions and reversed the court of appeals' holding that prior Missouri DWI convictions are not "comparable" to Kansas' driving under the influence of alcohol (DUI) offense for purposes of sentencing a defendant as a repeat DUI offender, holding that the district court should have considered Defendant's prior Missouri DWI convictions.Given Defendant's two prior Missouri DWI convictions, the State charged Defendant with felony DUI as a third-time offender. Defendant moved to strike her DWI convictions from the proceedings. The district court granted the motion to strike, concluding that Defendant's prior Missouri DWI offenses were not "comparable" to those in Kan. Stat. Ann. 8-1567 for purposes of determining whether Defendant was a repeat DUI offender. The State filed an interlocutory appeal. The court of appeals affirmed. The Supreme Court remanded this matter, holding (1) the district court erred in striking Defendant's prior Missouri DWI convictions; and (2) the court of appeals erred in concluding that prior Missouri DWI convictions are not "comparable" to Kansas' DUI offense for purposes of sentencing a defendant as a repeat DUI offender. View "State v. Myers" on Justia Law

The Supreme Court affirmed Defendant's statutory default sentence of life without the possibility of parole for fifty years, holding that there was no abuse of discretion.Defendant pled guilty to first-degree premeditated murder and seven other felony offenses. The court sentenced Defendant to a hard fifty life sentence for the first-degree premeditated murder. On appeal, Defendant argued that the district court erred by denying his motion to depart to a hard twenty-five life sentence. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant's departure motion. View "State v. Grable" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that Defendant failed to meet his burden to show that his sentences were illegal, holding that Defendant failed to show by a preponderance of the evidence that the prior convictions used to enhance his current sentence were constitutionally invalid.Defendant pled guilty to drug- and firearm-related crimes. Defendant later stipulated to several probation violations. The district court revoked Defendant's probation and imposed the underlying sentences. Defendant appealed, arguing that the district court erred in revoking his probation and imposing the underlying sentences and imposed an illegal prison sentence. The court of appeals affirmed, holding that the district court had the authority to revoke Defendant's probation and impose the underlying sentences and that Defendant failed to meet his burden to show his sentences were illegal. The Supreme Court affirmed, holding that Defendant's sentences were not illegal. View "State v. Roberts" on Justia Law

The Supreme Court affirmed the judgment of the district court summarily denying Defendant's pro se motion to correct an illegal sentence under Kan. Stat. Ann. 22-3504, holding that the district court did not err in denying the motion.After a 1996 jury trial, Defendant was convicted of first-degree murder and other crimes. In 2017, Defendant brought the instant pro se motion to correct an illegal sentence. The district court denied the motion without holding an evidentiary hearing. The Supreme Court affirmed, holding that Defendant's motion to correct an illegal sentence under section 22-3504 failed. View "State v. Valdez" on Justia Law

The Supreme Court affirmed the decision of the court of appeals vacating Defendant's sentence and affirming Defendant's convictions and rejecting other constitutional challenges to his sentence and restitution order, holding that the court of appeals did not err.After a jury trial, Defendant was convicted of two counts of aggravated robbery and eight counts of kidnapping. The district court sentenced Defendant to a presumptive 200-month term of immurement and ordered Defendant to pay restitution. The court of appeals affirmed Defendant's convictions but vacated his sentence, concluding that the district court erred in classifying Defendant's prior Michigan juvenile adjudication for armed robbery as a person felony. The Supreme Court affirmed, holding (1) the court of appeals property affirmed the district court's order denying Defendant's Batson challenge; and (2) Defendant's constitutional challenges to his sentence and restitution order are resolved by this Court's recent opinions addressing identical claims. View "State v. Brown" on Justia Law