Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court concluding that the State had not met its burden of establishing the application of an established exception to the warrant requirement in justifying the constitutionality of the warrantless search of Defendant’s purse and wallet, holding that the search was not permitted under any of the exceptions to the warrant requirement.This case arose from the action of law enforcement officers conducting a warrantless search of Defendant’s purse and wallet after an ambulance took her from the scene of an accident. The State argued that the plain-view exception and the officer’s administrative caretaking function of locating a driver’s license to complete an accident report justified the warrantless search. The trial judge granted Defendant’s motion to suppress, concluding that the search violated Defendant’s constitutional rights. The Supreme Court affirmed, holding that the warrantless search was not permitted under any exception to the warrant requirement, and therefore, the evidence seized during the search must be suppressed. View "State v. Evans" on Justia Law

The Supreme Court affirmed Defendant’s convictions for premeditated first-degree murder and criminal possession of a firearm by a convicted felon, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not commit reversible error by admitting evidence of Defendant’s prior domestic violence to show motive; (2) the trial court did not commit reversible error by denying Defendant’s request for jury instruction on the affirmative defense of self-defense and on the lesser-included offense of involuntary manslaughter; and (3) there was no prosecutorial error that required a harmlessness analysis. View "State v. Haygood" on Justia Law

The Supreme Court affirmed the decision of the Court of Appeals affirming the judgment of the district court convicting Defendant of attempted voluntary manslaughter, second-degree murder, and criminal possession of a firearm, holding that the district judge erred by failing to instruct the jury on imperfect self-defense involuntary manslaughter but that the error did not require reversal.On appeal, Defendant argued that the trial judge erred by not instructing the jury on a theory of imperfect self-defense involuntary manslaughter as a lesser included crime for the charge of second-degree murder. The Court of Appeals rejected the claim, ruling that such an instruction was not factually inappropriate. The Supreme Court affirmed but on different grounds, holding that the trial judge’s error in failing to instruct the jury on imperfect self-defense involuntary manslaughter as a lesser included offense of second-degree murder was not clear error. View "State v. Pulliam" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court ordering Defendant to pay $10,800 in restitution to a couple with whom Defendant and her daughter had been living at the time Defendant committed the crimes for which she was convicted, holding that Defendant should have been giving a hearing on the restitution issue.Defendant pled nolo contendere to two counts of interfering with law enforcement by falsely reporting a crime. After the district court sentenced Defendant, Defendant appealed the restitution order, arguing that the district court erred by declining to conduct a restitution hearing at which Defendant was present and by ordering a restitution plan that was unworkable. The court of appeals affirmed. The Supreme Court vacated the restitution order and remanded for the district court to conduct a restitution hearing, holding that the district court’s summary holding that the appropriate amount of restitution would necessarily exceed Defendant’s ability to pay was apparently based on an incorrect legal hearing. View "State v. Martin" on Justia Law

The Supreme Court affirmed the decision of the district court summarily denying Appellant’s motion to correct and illegal sentence, holding that Appellant’s claims could not be raised in a motion to correct an illegal sentence.In his motion, Appellant argued that his hard forty sentence was illegal because the sentencing jury considered inadmissible hearsay evidence and was wrongly instructed that it needed unanimously to recommend the hard fifteen sentence. The district court summarily denied Appellant’s motions, concluding that a motion to correct an illegal sentence was not the appropriate vehicle to raise his challenges to his sentence. The Supreme Court affirmed, holding that Appellant could not raise his arguments in his motion to correct an illegal sentence. View "State v. Alford" on Justia Law

The Supreme Court affirmed Defendant’s convictions of first-degree premeditated murder and criminal possession of a firearm, holding that there was no prejudicial error in the trial proceedings.Specifically, the Court held (1) there was no prosecutorial error during closing arguments where the evidence supported the prosecutor’s suggestion that Defendant’s testimony was unbelievable; (2) trial court did not abuse its discretion in overruling Defendant’s claim of racial discrimination during jury selection and in concluding that the prosecutor had a valid race-neutral reasons to strike each juror; and (3) trial court did not abuse its discretion in admitting gruesome autopsy photographs. View "State v. Williams" on Justia Law

The Supreme Court affirmed Defendant’s convictions for child abuse and felony murder, holding that the instances of prosecutorial error in this case did not require reversal, either individually or cumulatively.Specifically, the Court held that the prosecutor exceeded the wide latitude afforded to prosecutors on three occasions during closing argument, but the State proved beyond a reasonable doubt that the error did not affect the trial’s outcome in light of the entire record. Further, the Court held that the cumulative effective of the claimed errors did not deprive Defendant of a fair trial. View "State v. Anderson" on Justia Law

The Supreme Court reversed the decision of the Court of Appeals to dismiss Defendant’s appeal of the district court’s failure to modify his guideline sentence upon revocation of his probation and remanded to the Court of Appeals to reinstate the appeal, holding that the Court of Appeals erred in dismissing the appeal based on an incorrect determination that it lacked jurisdiction.Defendant was convicted of unlawful possession of hydrocodone. About halfway through his probation period, the State filed a motion to revoke Defendant’s probation. Prior to the hearing on that motion, Defendant filed a motion for resentencing upon revocation. The district court revoked probation, denied Defendant’s motion to modify his sentence, and imposed the original underlying sentence. The Court of Appeals dismissed Defendant’s appeal, concluding that it lacked jurisdiction to revise the district court’s decision on probation revocation disposition because the sentence imposed was a presumptive sentence. The Supreme Court reversed, holding that the Court of Appeals did have jurisdiction to hear Defendant’s appeal because the district court’s decision to deny Defendant’s motion for modification at that probation revocation hearing, leaving the original presumptive sentence in place, was appealable. View "State v. Weekes" on Justia Law

The Supreme Court affirmed Defendant’s jury trial convictions for premeditated first-degree murder, attempted premeditated first-degree murder, and other crimes, holding that the error in the proceedings below did not require reversal because Defendant’s right to a fair trial was not violated.On appeal, the Supreme Court identified three instances of prosecutorial error and also found that Defendant’s statutory right to be present at the hearing on his motion in limine was violated and that the district court erred in refusing to redact a video recording of Defendant’s law enforcement interview to remove references to a fifty-year sentence and the statements implying that Defendant had previously been in prison. The Supreme Court held that the errors, both in isolation and cumulatively, did not deprive Defendant of a fair trial. View "State v. Lowery" on Justia Law

The Supreme Court affirmed Defendant’s conviction of premeditated first-degree murder on retrial and his hard-twenty-five life sentence, holding that Defendant was not prejudiced by any errors so as to deny him a fair trial.In 2005, Defendant was convicted of premeditated first-degree murder. In 2012, the Court of Appeals granted Defendant's motion for postconviction relief and ordered a new trial. Upon retrial, a new jury also convicted Defendant of premeditated first-degree murder. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that actual prejudice from pretrial publicity mandated a reversal of his conviction; (2) Defendant failed to establish he was prejudiced by the trial court’s denial of his for-cause challenges to ten prospective jurors; (3) any error in the prosecutor’s violation of a limine order prohibiting any mention of pornography was harmless; and (4) Defendant was not substantially prejudiced by the cumulative effect of multiple errors. View "State v. Miller" on Justia Law