Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence seized after a traffic stop and a warrantless probable cause search of the vehicle, holding that the district court did not err in denying the motion to suppress.Defendant was the front seat passenger in a vehicle stopped by officers for a traffic violation. Officers began removing the vehicle's occupants to facilitate a drug dog sniff, called for because of the nature of the stop and the officers' previous knowledge of Defendant. Officers observed drug paraphernalia in Defendant's immediate vicinity and called off the dog sniff before it began. Thereafter, a warrantless probable cause search of the vehicle disclosed controlled substances. Defendant filed a motion to suppress, arguing that the officers detained the vehicle's occupants longer than lawfully permitted to accommodate the drug dog sniff. The district court denied the motion, and the court of appeals affirmed. The Supreme Court affirmed, holding that substantial competent evidence supported the district court's findings, and those findings supported the district court's legal conclusions. View "State v. Lutz" on Justia Law

The Supreme Court affirmed Defendant's conviction of ten counts of criminal conduct, including attempted capital murder, holding that a single error occurred in the proceedings below, and the error was harmless.Specifically, the Supreme Court held (1) there was no support for Defendant's claims that the district court impermissibly participated in plea negotiations and imposed consecutive sentences as "the product of judicial vindictiveness"; (2) the prosecutor made an incorrect statement during closing arguments, but the State met its burden to demonstrate that the error did not affect the trial's outcome beyond a reasonable doubt; and (3) the district court did not err in its response to a jury question. View "State v. Bowser" on Justia Law

The Supreme Court affirmed Defendant's convictions of first-degree murder and other offenses, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the State charged Defendant with an alternative means crime, and sufficient evidence supported both alternative means articulated in the court's jury instructions; (2) the district court did not err when it admitted into evidence Defendant's incriminating statements to police; and (3) Defendant failed to preserve for appellate review his argument that the district court erred by excluding evidence that Defendant delayed treatment for his injuries; (4) the prosecutor did not commit misconduct during voir dire; and (5) there was no inconsistency with the sentencing journal entry and the district court's oral pronouncement at the sentencing hearing. View "State v. Davis" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted capital murder, aggravated robbery, and other offenses, holding that there was no error during Defendant's trial.Specifically, the Supreme Court held (1) there was sufficient evidence presented by the State to support Defendant's convictions; (2) Defendant failed to designate a sufficient record to support his claim that the district court erred when it admitted the contents of his cell phone; (3) the district court did not err when it admitted Defendant's jail phone calls; (4) the district court properly admitted Kan. Stat. Ann. 60-455 prior crimes evidence; and (5) the district court properly admitted two timelines as evidence. View "State v. Meggerson" on Justia Law

The Supreme Court reversed the decision of the court of appeals panel that used a harmless error analysis to save a district court's denial of Defendant's motion to withdraw his plea even though the panel concluded that the court applied the wrong legal standard, holding the court of appeals erred in engaging in a harmless error analysis under the circumstances.Defendant pleaded no contest to robbery and aggravated assault. Before sentencing, Defendant filed a pro se motion to withdraw his plea, asserting ineffective assistance of counsel. The district court denied the motion. The panel concluded that the district court erred in using the Strickland test rather than the "lackluster advocacy" standard specified in State v. Aguilar, 231 P.3d 563 (Kan. 2010) but that the error was harmless. The Supreme Court reversed, holding that the analysis of the court of appeals was incorrect. View "State v. Herring" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of two counts of aggravated robbery, holding that the court of appeals did not err in holding that the convictions would not result in a subsequent prosecution and that Defendant was not twice put in jeopardy.Defendant took the property of three individuals in one incident. Defendant was convicted of two counts of aggravated robbery and one count of theft, each count relating to a different victim. On appeal, Defendant argued that the State divided one criminal offense into three crimes in violation of double jeopardy protections. The court of appeals reversed Defendant's theft conviction and otherwise affirmed. The Supreme Court affirmed, holding (1) the charges arose from unitary conduct; (2) the State did not violate double jeopardy protection by prosecuting Defendant a second time for aggravated robbery after his theft conviction had been affirmed; and (3) Defendant's aggravated robbery convictions were not multiplicitous. View "State v. Dale" on Justia Law

The Supreme Court held that, on judicial review under Kan. Stat. Ann. 8-1020(p) of a hearing officer's order suspending a driver's license, a court may consider any constitutional issue, including the lawfulness of the law enforcement encounter, and that, under section 8-1020(o)-(q), a court may set aside a driver's license suspension order if the driver meets the burden of establishing that the encounter was unlawful.Defendant was arrested for driving under the influence. When Defendant refused to provide a breath sample his driver's license was suspended. A district court judge set aside the suspension based on his determination that the law enforcement encounter was unlawful. The court of appeals affirmed. The Supreme Court affirmed, holding that the stop was unlawful and violated Defendant's constitutional rights, and therefore, the district court did not err in setting aside the suspension of Defendant's driver's license. View "Jarvis v. Kansas Department of Revenue" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder and battery, holding that there was no reversible error on the part of the district court.After a jury trial, Defendant was found guilty of first-degree murder and battery. The district court imposed a hard fifty sentence for the murder conviction and a concurrent six-month sentence for the battery conviction. The Supreme Court affirmed, holding (1) Defendant's challenges to certain jury instructions were unavailing; (2) several statements made by the prosecutor challenged by Defendant on appeal fell within the broad discretion afforded prosecutors; (3) the trial court did not abuse its discretion in admitting certain evidence; and (4) there was no sentencing error. View "State v. Willis" on Justia Law

The Supreme Court affirmed the decision of the district court summarily denying Defendant's postsentence motion to modify sentence, holding that no legal avenue existed for the relief requested by Defendant.Defendant was convicted of premeditated first-degree murder and three counts of aggravated assault. The district court sentenced Defendant to a hard forty life sentence on the murder charge and added thirteen additional months in prison for the aggravated assault charges. On appeal, the Supreme Court remanded for resentencing on the murder charge. On remand, Defendant was again sentenced to a hard forty life time for first-degree murder. The Supreme Court affirmed. Defendant later filed a pro se motion seeking to have his hard forty life sentence modified to require no mandatory term of imprisonment, arguing that his sentence violated the Sixth Amendment because the trial judge and not a jury made the factual findings necessary for sentence enhancement. The district judge denied the motion. The Supreme Court affirmed, holding that Alleyne v. United States, 570 U.S. 99 (2013), and State v. Soto, 322 P.3d 334 (2014), did not operate retroactively to provide a remedy in this case and that Kan. Stat. Ann. 21-6628(c) did not apply. View "State v. Coleman" on Justia Law

The Supreme Court reversed Defendant's conviction of first-degree premeditated murder, holding that the district court erred in not instructing the jury on self-defense and that the error was reversible.At the close of the evidence, Defendant requested jury instructions on self-defense and involuntary manslaughter. The court declined to give the requested instructions, finding that the evidence failed to support either instruction. On appeal, Defendant argued that the district court committed reversible error when it refused to give his requested instructions. The Supreme Court reversed, holding that Defendant's testimony sufficed to make a self-defense instruction factually appropriate and that the district court's error in refusing to give the instruction was reversible. View "State v. Keyes" on Justia Law