Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's convictions for felony murder, intentional second-degree murder, felony theft of a firearm, felony theft of a vehicle, and burglary, holding that there was no error in the proceedings below.On appeal, Defendant raised three arguments attacking the sufficiency of the State's evidence supporting his convictions. The Supreme Court affirmed, holding (1) the evidence, viewed in a light most favorable to the State was sufficient to support the convictions, and the jury was not required to stack inferences in convicting Defendant; and (2) the district court did not err in denying Defendant's request for a lesser included offense instruction on voluntary manslaughter. View "State v. Colson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction for failure to register under the Kansas Offender Registration Act (KORA), holding that the court of appeals panel erred when it declined to review Defendant's claim challenging her duty to register under the invited error doctrine, but the argument failed on the merits.During trial, Defendant filed a motion arguing that the State would need to prove she had a culpable mental state when she failed to register. The district court denied the motion, concluding that failure to register was a strict liability crime. The court of appeals affirmed, rejecting Defendant's defense of substantial compliance. The Supreme Court affirmed, holding (1) substantial compliance is not an available defense to a charge of failure to register under KORA; (2) the unavailability of a substantial compliance defense did not violate Defendant's due process rights; (3) Defendant had standing to challenge KORA on its face as unconstitutional; and (4) while the court of appeals erred when it held that Defendant could not challenge the sufficiency of the State's evidence because she invited any error, Defendant's claim still failed on the merits. View "State v. Stoll" on Justia Law

The Supreme Court affirmed Defendant's conviction for methamphetamine possession after he pled no contest to that offense, holding that the district court properly denied Defendant's motion to dismiss for violation of the Uniform Mandatory Disposition of Detainers Act (UMDDA), Kan. Stat. Ann. 22-4301 et seq.On appeal, Defendant argued that the district court lost jurisdiction under the UMDDA because he was not timely brought to trial. The court of appeals rejected Defendant's claim. The Supreme Court affirmed, holding that Defendant's argument that an inmate's substantial compliance always starts the UMDDA's 180-day time limit despite the plain statutory language was unavailing. View "State v. Griffin" on Justia Law

The Supreme Court affirmed the decision of the court of appeals vacating Defendant's sentence, holding that a reasonable person would not find Defendant's acceptance of responsibility to be a compelling reason to override the statutory presumptive sentence of imprisonment.Defendant pled no contest to securities fraud and acting as an unregistered issuer agent. The district court granted a dispositional departure to probation from a presumptive sentence of imprisonment. The court of appeals reversed and remanded the case for resentencing, concluding that there was not a substantial and compelling reason to support departure. The Supreme Court affirmed, holding that no reasonable person would find that the limited responsibility Defendant took rendered Defendant's case a compelling deviation from the norm the legislature has established. View "State v. Morley" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder and aggravated battery, holding that none of Defendant's allegations of error required reversal of his convictions.Specifically, the Supreme Court held (1) the district court erred in ruling on Defendant's motion for immunity under Kan. Stat. Ann. 21-5231, and the appropriate remedy was to review the record of the original hearing to determine whether the State satisfied its burden to show probable cause that Defendant's use of deadly force was not statutorily justified; (2) the State showed probable cause under the totality of the circumstances; (3) the district court properly denied Defendant's request for a lesser included offense instruction to the aggravated battery charge; and (4) the district court did not err in denying Defendant's motion for new trial. View "State v. Phillips" 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

The Supreme Court reversed Defendant's conviction of one count of aggravated arson, holding that where the State charged three identical counts of aggravated arson and the jury instructions and verdict form failed to distinguish those counts, this Court was unable to reliably associate particular conduct with the count of conviction, frustrating appellate review and adversely implicating Defendant's due process rights.Defendant was charged with three counts of aggravated arson. All charges were alleged to have occurred at different times. The jury convicted Defendant of one count and acquitted him of the other two. The Supreme Court reversed the conviction and remanded the case for further proceedings, holding that because it was impossible to determine the jury's verdict as to which crime if found Defendant guilty of beyond a reasonable doubt, this Court's confidence in the propriety of Defendant's conviction for this criminal charge is undermined by concerns for Defendant's due process rights. View "State v. Coble" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion for a downward durational departure from the presumptive hard fifty sentence for his convictions for two counts of first-degree premeditated murder, holding that the court did not abuse its discretion.Defendant pled no contest to two counts of first-degree premeditated murder, felony theft, and interference with law enforcement. Before sentencing, Defendant unsuccessfully moved for a downward durational departure from the presumptive hard fifty sentence for the murders. The district court denied the motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant's motion for a downward durational departure. View "State v. McNabb" on Justia Law

The Supreme Court declined to retain Appellant's appeal under the "unique circumstances doctrine" and refused to make factual findings, holding that remand was required for factual findings regarding the circumstances of the untimeliness of Appellant's notice of appeal.Appellant was convicted of first-degree murder and other crimes. Later, Appellant filed a motion to correct an illegal sentence and argued that he was entitled to relief under Kan. Stat. Ann. 60-1507. The district judge denied the motion. Appellant filed a late notice of appeal, but the district judge did not make any findings on the record about the circumstances of the untimely appeal on the record. The Supreme Court remanded the case to the district court for further proceedings, holding (1) because the unique circumstances doctrine was eliminated as a source of appellate jurisdiction in 2011 it could not serve as a basis for jurisdiction in this case; and (2) maintaining jurisdiction on other due process-related grounds would require this Court to make factual findings, which this Court declines to do. View "State v. Hooks" on Justia Law

The Supreme Court affirmed the Defendant's convictions of premeditated first-degree murder and two counts of cruelty to animals, holding that there was no error in the proceedings below.Specifically, the Supreme Court held that the district court (1) erred when it included additional information in the standard premeditation Pattern Instructions for Kansas instruction; (2) did not err when it failed to instruct the jury on heat of passion voluntary manslaughter; (3) certain testimony did not violate Defendant's rights under the Confrontation Clause; and (4) because there was no error, cumulative error did not deny Defendant a fair trial. View "State v. Stafford" on Justia Law