Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals reversing Defendant's convictions on two counts of aggravated criminal sodomy, holding that Defendant received deficient representation pretrial and at trial and that Defendant was prejudiced as a result.After Defendant's conviction was affirmed on direct appeal he filed a Kan. Stat. Ann. 60-1507 motion alleging that trial and appellate counsel provided ineffective assistance. The court of appeals concluded that Defendant's counsel had not met the constitutional standard for effective assistance of trial or appellate counsel and that Defendant was prejudiced as a result. The Supreme Court affirmed, holding that trial counsel's decision to drop a pretrial challenge to the admissibility of Defendant's incriminating statements and counsel's failure to object to certain evidence being admitted at trial constituted ineffective assistance of counsel. View "Khalil-Alsalaami v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing Defendant's conviction of one count of criminal threat under Kan. Stat. Ann. 21-5415(a)(1), holding that there was no basis for this Court to discern whether the jury concluded the State had proved beyond a reasonable doubt that Defendant committed criminal threat intentionally.On appeal, the court of appeals concluded that the trial court erred by rejecting defense counsel's proposed jury instruction on workplace defense. The State sought review. While review was pending, the Supreme Court held in State v. Johnson, 450 P.3d 790 (Kan. 2019), that the provision in section 21-5415(a)(1) allowing conviction if a threat of violence was made in reckless disregard for causing fear was unconstitutionally overbroad. The Supreme Court affirmed the court of appeals' judgment as right for the wrong reason, holding that, based on Johnson, Defendant's conviction cannot stand. View "State v. Lindemuth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court ordering Defendant to register as a violent offender under the Kansas Offender Registration Act (KORA), Kan. Stat. Ann. 22-4901 et seq., holding that the district court's notice to Defendant concerning his obligation to register did not violate Defendant's right to due process.Defendant was convicted and sentenced for aggravated burglary. The district court ordered Defendant to register as a violent offender under KORA. On appeal, Defendant argued that the district court's failure to notify him of his registration obligation at the time of his plea and conviction violated his right to procedural due process under the Fourteenth Amendment. The Supreme Court disagreed, holding that the notice provided to Defendant was constitutionally sound and that Defendant was not deprived of his opportunity to be heard. View "State v. Juarez" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony murder, aggravated assault, felony discharge of a firearm, and aggravated endangering of a child, holding that no reversible error occurred.Defendant was convicted of felony murder based on the underlying inherently dangerous felonies of criminal discharge of a firearm at an occupied dwelling and aggravated endangering of a child. The Supreme Court affirmed Defendant's conviction and sentence for felony murder, holding (1) the underlying felonies supported Defendant's convictions and sentences; and (2) Defendant's claims that the trial judge erred in instructing the jury lacked merit. View "State v. Pattillo" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree premeditated murder, aggravated burglary, and arson, holding that no error required reversal.Specifically, the Supreme Court held (1) the district court judge did not err by refusing to give a voluntary intoxication instruction or a voluntary manslaughter instruction; (2) Defendant failed to preserve for appeal his argument that the district judge erred in admitting a videotaped interrogation of him into evidence because law enforcement agents repeatedly challenged his honesty and truthfulness during that interrogation; and (3) the district judge did not err in refusing to give a cautionary instruction on informant testimony. View "State v. Green" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree premeditated murder, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) even if a challenged remark by the prosecutor constituted prosecutorial error, there was no possibility that it contributed to the verdict; (2) the district court did not err in admitting cell tower maps and accompanying testimony; (3) the district court did not commit clear error in failing sua sponte to instruct the jury on intentional second-degree murder as a lesser included offense of premeditated first-degree murder; and (4) the district court's failure to give any lesser included instructions did not violate Defendant's due process rights. View "State v. Timley" on Justia Law

The Supreme Court affirmed the decision of the Court of Appeals reversing the judgment of the district court denying Defendant's motion to suppress drug-related evidence, holding that that the Court of Appeals correctly denied the motion to suppress.Defendant was charged with possession of methamphetamine and possessing drug paraphernalia. Defendant filed a motion to suppress, arguing that she was unlawfully detained. In response, the State argued that the attenuation doctrine legitimized the seizure. The Court of Appeals reversed, holding that the investigatory detention of Defendant exceeded the scope of the initial welfare check. The Supreme Court affirmed, holding (1) where the police officer had no reasonable suspicion that Defendant was committing, had committed, or was about to commit a crime the officer's conduct constituted an unlawful seizure and consequent search; and (2) the facts of this case rendered application of the attenuation doctrine inappropriate. View "State v. Ellis" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree premeditated murder and other crimes, holding that the prosecutor did not err during closing arguments by saying, "The defense has speculated about other peoples [sic] motives, but the State has actually presented evidence."On appeal, Defendant argued that the prosecutor impermissibly shifted the burden of proof from the State to the defense and infringed on his constitutional protections against compulsory self-incrimination. The Supreme Court disagreed, holding that the prosecutor's comments did not offend Defendant's constitutional right to a fair trial and did not fall outside the wide latitude afforded prosecutors to conduct the State's case. View "State v. Martinez" on Justia Law

The Supreme Court reversed Defendant's conviction for aggravated battery but affirmed his convictions for abuse of a child and aggravated endangering of a child, holding that the cumulative effect of certain errors required reversal of the aggravated battery conviction.Specifically, the Supreme Court held (1) the district court erred by giving jury instructions that allowed the jury to convict Defendant of aggravated battery if it found that Defendant intended the conduct but not the harm; (2) during closing arguments, the prosecutor erred by telling jurors to acquit only if the jurors thought it was acceptable to inflict injuries on their children; and (3) the two errors when considered together were not harmless as to the aggravated battery conviction. Further, the Supreme Court held the district court erred by scoring a previous out-of-state conviction from Virginia for domestic assault and battery as a person crime. View "State v. Thomas" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that Defendant did not establish that he was prejudiced by his counsel's performance, holding that Defendant met his burden of showing that there was a reasonable probability that, but for his trial counsel's deficient performance, the result of his trial would have been different.Defendant was convicted of second-degree murder. The court of appeals affirmed. Defendant later moved to have his conviction set aside, arguing that his appointed trial counsel provided ineffective assistance by failing to admit into evidence a recording of a 911 call in which the caller identified someone other than Defendant as the person who killed the victim. The district court denied relief, and the court of appeals affirmed. The Supreme Court reversed, holding (1) counsel's failure to introduce the 911 call fell below an objective standard for reasonably effective representation; and (2) Defendant was prejudiced by his counsel's deficient performance. View "Balbirnie v. State" on Justia Law