Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's sentence of death imposed in connection with his conviction for capital murder, holding that the sentence was not "imposed under the influence of passion, prejudice or any other arbitrary factor." See Kan. Stat. Ann. 21-6619(c)(1).Defendant was convicted of capital murder and sentenced to death. The Supreme Court affirmed the convictions but vacated the death sentencing, holding that the failure to sever the penalty phase violated Defendant's right to an individualized sentencing determination under the Eighth Amendment. However, in Kansas v. Carr, 477 U.S. 108 (2016), the United States Supreme Court held that the trial court's failure to Defendant's penalty phase did not implicate either the Eighth Amendment or the Due Process Clause. On remand, the Supreme Court addressed penalty phase issues that remained unresolved. The Court then affirmed Defendant's sentence, holding that Defendant received a fair trial and that any mitigating circumstances were insufficient to outweigh the aggravating circumstances. View "State v. Carr" on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendant's motion for a sentence modification under Kan. Stat. Ann. 21-6628(c) and denied Defendant's newly raised claim of an illegal sentence, holding that Defendant was not entitled to relief.Defendant was convicted of first-degree murder and sentenced to a hard forty sentence. Defendant later filed a pro se motion for sentence modification pursuant to Kan. Stat. Ann. 21-6628(c), which the district court denied. The Supreme Court affirmed the denial, holding (1) the district court did not err in denying Defendant's motion for sentence modification; and (2) Defendant's argument raised for the first time on appeal that his sentence was illegal because the sentencing court did not comply with a statutory direction to designate the aggravating circumstances in writing was without merit. View "State v. Bedford" on Justia Law

The Supreme Court affirmed Defendant's conviction for possession of methamphetamine for insufficient evidence, holding that the evidence was sufficient to support the conviction and that Defendant could not challenge the underlying search of the vehicle in which he was a passenger.On appeal, the court of appeals reversed Defendant's conviction of methamphetamine possession for insufficient evidence based on the parties' stipulation of facts. The Supreme Court reversed, holding that the court of appeals (1) erred in concluding that Defendant's conviction was not supported by sufficient evidence; and (2) correctly concluded that Defendant's status as a passenger did not confer standing for purposes of the Fourth Amendment to challenge the search of the car. View "State v. Scheuerman" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the district court's decision to revoke Defendant's probation, holding that the district court failed to follow the statutory graduated sanctions set out in Kan. Stat. Ann. 22-3716.Section 22-3716 requires judges, except under certain circumstances set forth in a bypass exception, to impose specified intermediate sanctions before revoking a defendant's probation. In the instant case, Defendant committed multiple probation violations and received sanctions on two prior occasions. After a third violation, a district court judge revoked Defendant's probation without mentioning the bypass exception. The Supreme Court remanded the case, holding that the harmless error analysis does not apply to the district court's failure to follow the statutory graduated sanctions set forth in section 22-3716. View "State v. Wilson" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, holding that the errors committed during Defendant's trial did not affect the jury's verdict.Specifically, the Supreme Court held (1) there was no error in the admission of an autopsy photograph; (2) the prosecutor erred in closing argument by repeatedly use the phrase "we know" before discussing controverted facts, but the error was harmless; (3) presuming that the district court erred in not instructing the jury on the limited purpose for which the judge admitted some evidence, the error did not affect the verdict; (4) there was no error when the district court listed the jury's choice of finding Defendant guilty before listing the option of not guilty on the verdict form; and (5) the cumulative errors in this case did not affect the outcome. View "State v. Alfaro-Valleda" on Justia Law

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