Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court judge denying Defendant's motion for a new trial on the basis of DNA testing results, holding that the district judge did not abuse her discretion by concluding that there was no "reasonable probability" the DNA results would have changed the original trial's outcome.Defendant was convicted of first-degree murder, conspiracy to possess with intent to sell hallucinogenic drugs, and aggravated robbery. Approximately a dozen years later, Defendant filed a request for DNA testing on some items found at the crime scene. The district judge granted the request. Defendant filed a motion to set aside his conviction or grant him a new trial in light of the DNA test results. The district judge denied the motion, concluding that the new DNA evidence was "not reasonably probable to lead to a jury reaching a different result." The Supreme Court affirmed, holding that the district judge did not abuse her discretion in denying relief. View "State v. Edwards" on Justia Law

The Supreme Court affirmed the decision of the trial court denying Defendant's pro se motion styled as a "Motion to Set Aside a Void Judgment under Due Process of Law and K.S.A. 22-3210," holding that the trial court correctly analyzed the motion as a motion to withdraw plea under Kan. Stat. Ann. 22-3210 and did not err in denying the motion as untimely.In 2000, Defendant pleaded guilty to premeditated first-degree murder and other crimes. In 2017, Defendant filed the motion that was the subject of this appeal. The trial court construed Defendant's motion as one to withdraw his plea under section 22-3210 and denied it as untimely. Defendant appealed, arguing that the trial court erred in analyzing his motion as one to withdraw his plea instead of analyzing it as a motion to void his convictions and sentences and that he was denied due process during the plea process. The Supreme Court affirmed, holding (1) the trial court correctly analyzed the motion as one to withdraw plea; and (2) where Defendant neither asserted nor demonstrated any grounds of excusable neglect, the motion was procedurally barred. View "State v. Hill" on Justia Law

The Supreme Court affirmed Defendant's convictions of possession of marijuana and cocaine, holding that the district court did not err in allowing Defendant to exercise her constitutional right of self-representation where the record did not establish that Defendant suffered from a severe mental illness.On appeal, Defendant argued that the district court judge used the incorrect standard to determine whether she was competent to represent herself. The court of appeals affirmed. The Supreme Court affirmed, holding that, without an indication that Defendant suffered from a severe mental illness, there was no basis to conclude that the district court judge abused his discretion when he allowed Defendant to waive her right to counsel and represent herself at trial. View "State v. Burden" on Justia Law

The Supreme Court affirmed as right for the wrong reason the judgment of the court of appeals holding that harmless constitutional error occurred when the district court responded to a jury question by having court staff deliver a written note to the jury room rather than convening in open court and answering the question in Defendant's presence, holding that no constitutional error occurred.Specifically, the court of appeals held that the district court violated Defendant's constitutional right to be present at a critical stage in the proceedings by responding in writing to the jury rather than giving the answer with Defendant present in the open court but that the error was harmless. The Supreme Court affirmed, holding (1) Kan. Stat. Ann. 22-3420(d) gave the district court discretion to deliver a written response to the jury room without having Defendant present; and (2) no constitutional error occurred in this case. View "State v. Harrison" on Justia Law

The Supreme Court held that the uncertainty in the residual phrase in Kan. Stat. Ann. 21-6304 defining a knife as "a dagger, dirk, switchblade, stiletto, straight-edged razor or any other dangerous or deadly cutting instrument of life character" is so great that the law is impermissibly and unconstitutionally vague.Defendant, a convicted felon, was found guilty of criminal possession of a weapon stemming from his act of pulling out a pocketknife when he got into an altercation with another man. On appeal, Defendant argued that the district court erred by rejecting his vagueness challenge to section 21-6304, which makes it a crime for a convicted felon to possess a knife. The court of appeals affirmed. The Supreme Court reversed Defendant's conviction, holding that section 21-6304 invites "varying and unpredictable" enforcement decisions on an "ad hoc and subjective basis" and, therefore, the residual clause in section 21-6304 is unconstitutionally vague. View "State v. Harris" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree felony murder, criminal discharge of a firearm, aggravated battery, and criminal threat, holding that any error during the proceedings below was harmless.On appeal, Defendant argued that the district court erred by (1) declining to give his proffered instruction clarifying the definition of aiding and abetting, and (2) erred in granting the State's motion to consolidate his charges for trial. The Supreme Court affirmed, holding (1) any possible error in failing to give Defendant's requested jury instruction on aiding and abetting was harmless; and (2) the district court did not abuse its discretion in consolidating Defendant's charges for trial. View "State v. Carter" on Justia Law

The Supreme Court affirmed Defendant's convictions for, among other things, possession of methamphetamine with intent to distribute and possession of oxycodone, holding that the trial court's admission of Kan. Stat. Ann. 60-455 was evidence was not error and that sufficient evidence supported Defendant's possession of oxycodone conviction.On appeal, Defendant argued (1) the trial court erred in admitting section 60-455 evidence related to two prior methamphetamine sales to undercover detectives approximately one week before his arrest, (2) the trial court clearly erred in instructing the jury on possession of oxycodone, and (3) his conviction for possession of oxycodone was supported by insufficient evidence. The Supreme Court affirmed, holding (1) the district court did not err in admitting the prior crimes evidence; (2) invited error precluded Defendant's jury instruction claim; and (3) sufficient evidence supported Defendant's conviction for possession of oxycodone. View "State v. Brazzle" on Justia Law

The Supreme Court affirmed Defendant's grid-sentence, holding that, under two of this Court's recent opinions, Defendant failed to establish that the district court imposed an illegal sentence for purposes of Kan. Stat. Ann. 22-3504.In 1999, Defendant was convicted of capital murder, aggravated robbery, aggravated burglary, and two counts of felony theft. The district court imposed a hard forty sentence for Defendant's capital murder conviction, an off-grid crime, and to upward departure sentences on the grid crimes. The Supreme Court vacated Defendant's upward durational departure sentences for his grid crimes under Apprendi v. New Jersey, 530 U.S. 466 (2000) and resentenced Defendant. Defendant later filed a motion to correct na illegal sentence challenging his hard forty sentence. The district court denied the motion. The Supreme Court affirmed, holding that State v. Murdock, 439 P.3d 307 (Kan. 2019), and State v. Weber, 442 P.3d 1044 (Kan. 2019), foreclosed Defendant's challenge. View "State v. Bradford" on Justia Law

The Supreme Court affirmed Defendant's convictions of child abuse and felony murder with the underlying felony of child abuse but vacated the imposition of lifetime postrelease supervision, holding that the trial court did not err in convicting Defendant but erred in imposing lifetime postrelease supervision.Specifically, the Court held (1) the evidence provided sufficient proof to show that Defendant's action was knowingly done and cruel as required by Kan. Stat. Ann. 21-5602(a)(3); (2) the court did not err in instructing the jury "If you have no reasonable doubt as to the truth of each of the claims required to be proved by the State, you should find the defendant guilty"; and (3) the court improperly ordered lifetime postrelease supervision. View "State v. Gibson" on Justia Law

The Supreme Court affirmed Defendant's convictions for driving under the influence and illegal transportation of liquor, holding that "manifest necessity" is the correct measure for declaring a jury deadlocked under the United States Supreme Court's double jeopardy caselaw when the defendant does not object or consent to the mistrial.Defendant's first trial ended in a mistrial without Defendant's consent because of a jury deadlock. After a second jury trial, Defendant was convicted. Defendant appealed, arguing (1) his second trial violated his constitutional right against double jeopardy, and (2) the jury instruction on the State's burden of proof improperly discouraged the jury from exercising its nullification power. The court of appeals affirmed. The Supreme Court affirmed, holding (1) when a trial sua sponte declares a jury deadlocked and orders a mistrial when the defendant does not object or consent to the mistrial, retrial should be permitted only when there was a manifest necessity for the court's action, and the holding in State v. Graham, 83 P.3d 143 (Kan. 2004), to the contrary is overruled; (2) the district court properly declared a mistrial under the circumstances of this case based on the manifest necessity standard; and (3) Defendant's jury instruction challenge is rejected. View "State v. Kornelson" on Justia Law