Justia Kansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
State v. Goodro
The Supreme Court affirmed Defendant's convictions of felony possession of methamphetamine, misdemeanor possession of drug paraphernalia with intent to use, and misdemeanor theft, holding that the district court did not err in denying Defendant's motion to suppress.Defendant was detained at Walmart for trying to leave the store without paying for merchandise. Defendant was arrested and taken to jail, where a booking deputy conduct an inventory search of Defendant's possessions. Upon discovering illicit drugs the deputy did a strip search of Defendant's person, discovering more illicit drugs. Defendant moved to suppress the drugs and paraphernalia based on an illegal misdemeanor arrest. The motion was denied, and Defendant was convicted. On appeal, Defendant argued that the evidence should have been suppressed because the officer illegally arrested her rather than issuing her a notice to appear. The Supreme Court affirmed, holding that the officer had probable cause to believe Defendant committed misdemeanor theft and would not be apprehended. View "State v. Goodro" on Justia Law
Drennan v. State
The Supreme Court affirmed the judgment of the district court denying Defendant's motions filed under Kan. Stat. Ann. 60-1507 and Kan. Stat. Ann. 22-3504, holding that Defendant's section 60-1507 motion was untimely and successive and that Defendant's sentence was not illegal.In 2003, Defendant was convicted by a jury of first-degree murder and sentenced to a hard fifty life sentence. Since his conviction, Defendant filed multiple collateral attacks on his sentence and conviction, all of which were unsuccessful. In the motions at issue on appeal, Defendant alleged that his sentence was unconstitutional under Apprendi v. New Jersey, 530 U.S. 466 (2000) and that this Court's failure to correct his sentence violated Kan. Stat. Ann. 21-6628(c). The district court denied both motions. The Supreme Court affirmed, holding that the district court did not err in denying the motions. View "Drennan v. State" on Justia Law
Posted in:
Constitutional Law, Criminal Law
State v. Gleason
The Supreme Court affirmed the judgment of the district court denying Defendant's motion to set aside a void judgment under Kan. Stat. Ann. 60-260(b)(4) and his motion to correct an illegal sentence under Kan. Stat. Ann. 22-3504, holding that Defendant's argument on appeal was not legally sound.Defendant, an inmate serving a life sentence for first-degree felony murder, filed a motion to set aside a void judgment and a motion to correct an illegal sentence, arguing that his sentence was void and illegal because the State initially charged him with an offense outside of the statute of limitations, depriving the district court of jurisdiction over all later proceedings. The Supreme Court affirmed, holding that the statute of limitations is not a jurisdictional bar, and therefore, the complaint was never void, and Defendant's sentence was not illegal. View "State v. Gleason" on Justia Law
Posted in:
Criminal Law
State v. Evans
The Supreme Court affirmed the judgment of the district court entering judgment upon the jury's verdict and convicting Defendant of first-degree murder, aggravated battery, and criminal possession of a weapon, holding that Defendant received constitutionally effective assistance of counsel.After he was convicted, Defendant filed a post trial motion alleging several instances of ineffective assistance of trial counsel. The district court denied the motion after holding an evidentiary hearing. The Supreme Court affirmed, holding that the record showed that trial counsel (1) did not coerce Defendant or his witnesses to change their testimony about the events leading up to the murder; and (2) did not disregard the firearm expert's testimony regarding the functionality of the victim's gun. View "State v. Evans" on Justia Law
Posted in:
Criminal Law
State v. Green
The Supreme Court affirmed the sentence imposed by the district court in connection with his plea of guilty to two counts of felony first-degree murder, with kidnapping as the underlying felony, holding that there was no reversible error in the sentencing proceedings.Pursuant to a plea agreement, Defendant and the State agreed to request presumptive hard twenty-five sentences. After a sentencing hearing, the court imposed consecutive hard twenty-five sentences. The Supreme Court affirmed, holding (1) substantial competent evidence supported the factual determination that Defendant committed the crimes in the hope of receiving financial compensation; and (2) there was no reversible error in the trial court's denial of Defendant's motion to continue. View "State v. Green" on Justia Law
Posted in:
Criminal Law
Denney v. Norwood
The Supreme Court affirmed the ruling of the court of appeals affirming the judgment of the district court dissolving a writ of habeas corpus and finding that Appellant was properly classified as a sex offender under Kansas Department of Corrections (KDOC) policy, holding that summary dismissal was proper under Kan. Stat. Ann. 60-1505.In his habeas petition, Appellant alleged that KDOC improperly classified him as a sex offender under the Kansas Offender Registration Act (KORA), Kan. Stat. Ann. 22-4901 et seq. The district court found that Appellant was properly classified as a sex offender under KDOC policy rather than KORA. A panel of the court of appeals affirmed. The Supreme Court affirmed, holding (1) the panel erred by analyzing the district court's ruling under Kan. Stat. Ann. 60-212; but (2) summary dismissal was proper under section 60-1505. View "Denney v. Norwood" on Justia Law
Posted in:
Criminal Law
State v. Mitchell
The Supreme Court affirmed the judgment of the district court denying Defendant's pro se motion to correct an illegal sentence, holding that the district court did not err in summarily denying Defendant's motion.A jury convicted Defendant of aggravated burglary, aggravated kidnapping, rape, and two counts of aggravated sodomy. Defendant later filed a pro se motion to correct an illegal sentence under Kan. Stat. Ann. 22-3504, arguing that his sentence was illegal because he was denied his statutory right to a speedy trial and his right to allocution at sentencing. The district court denied the motion without holding an evidentiary hearing. The Supreme Court affirmed, holding that neither of Defendant's claims was properly before the court in a motion to correct an illegal sentence. View "State v. Mitchell" on Justia Law
State v. Shields
The Supreme Court affirmed the order of the district court denying Defendant's postsentencing motion to withdraw his plea of no contest to first-degree felony murder, holding that Defendant did not meet his burden to establish that the district court abused its discretion.In his motion, Defendant argued that he did not fairly and knowingly enter the plea because his attorney provided ineffective representation by withholding discovery materials and not giving him sufficient time to review the plea agreement. The district court denied the motion, concluding that Defendant failed to show a manifest injustice. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant's plea withdrawal motion. View "State v. Shields" on Justia Law
Posted in:
Criminal Law
State v. Smith
The Supreme Court affirmed the judgment of the district court denying Defendant's motion to withdraw plea, which Defendant filed approximately seven years after he was convicted, holding that the district court did not err in denying Defendant's motion without an evidentiary hearing.Defendant was convicted of first-degree murder on a plea contest. Roughly seven years after he was convicted, Defendant filed his motion to withdraw plea. The district court ruled that the motion was untimely and that Defendant had failed to make an affirmative showing of excusable neglect to extend the deadline. The Supreme Court affirmed, holding that Defendant failed to establish excusable neglect for the delayed filing. View "State v. Smith" on Justia Law
Posted in:
Criminal Law
State v. Gulley
The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and aggravated robbery and his resulting sentences, holding that there was no reversible error.Defendant was found guilty by a jury of committing first-degree premeditated murder and aggravated robbery when he was fifteen years old. Defendant was sentenced life imprisonment for the murder conviction and a consecutive sixty-one months' term of imprisonment for the robbery conviction. The Supreme Court affirmed, holding (1) the district court did not err by not giving an instruction on voluntary manslaughter-heat of passion; (2) Defendant failed to show that the prosecutor erred; and (3) Defendant's sentence did not violate the Eighth Amendment's prohibition of cruel and unusual punishment under the principles announced in Miller v. Alabama, 567 U.S. 460 (2012). View "State v. Gulley" on Justia Law