Justia Kansas Supreme Court Opinion Summaries

In 2000, at the age of eighteen, Defendant was convicted as an adult of murder. In 2012, Defendant filed a second petition for collateral relief, alleging ineffective assistance of counsel and denial of due process because he was convicted while mentally incompetent. Although Defendant’s motion was entitled “Motion to Correct Illegal Sentence,” the district court deemed the motion a collateral challenge under Kan. Stat. Ann. 60-1507 and assigned it both a civil case number and a criminal case number. In the civil case, the court summarily denied the motion, determining that the pleading was both untimely and successive. In the criminal case, the court dismissed the motion, concluding that it was without merit. Defendant filed two notices of appeal, one to the Court of Appeals from the civil decision and one to the Supreme Court from the criminal caption. The Court of Appeals affirmed. In his appeal to the Supreme Court, Defendant argued that his conviction amounted to a denial of due process because, at the time of trial, he was a juvenile who suffered from a mental defect that rendered him incompetent. The Supreme Court also affirmed, holding that because Defendant's claim was procedural, not jurisdictional, Defendant could not prevail in his claim that his sentence was illegal. View "State v. Jones" on Justia Law

After a trial, Defendant was convicted of capital murder. The district court imposed the mandated sentence of lifetime imprisonment without the possibility of parole. The Supreme Court affirmed the conviction, holding (1) the district court did not err when it failed to order sua sponte a competency evaluation; (2) the district court did not abuse its discretion by failing to inquire further into Defendant’s reasons for filing motions requesting the appointment of new counsel; and (3) Defendant’s claim that the district court judge allegedly misspoke during his reading of the instructions to the jury was without merit. View "State v. Marshall" on Justia Law

After a jury trial, Defendant was found guilty of premeditated first-degree murder and sentenced to a hard fifty sentence. The Supreme Court affirmed Defendant’s conviction but vacated his sentence and remanded for resentencing, holding (1) the sentencing scheme under which Defendant was sentenced has been declared to be unconstitutional, and therefore, Defendant must be resentenced; (2) this was not a multiple acts case requiring a unanimity instruction; (3) the district court properly denied Defendant’s motion arguing ineffective assistance of counsel; (4) the prosecutor’s statements during closing argument were in error, but the error was harmless; (5) Defendant was not convicted in violation of the corpus delicti rule; (6) the evidence was sufficient to support the conviction; (7) the district court correctly denied Defendant’s motion to suppress the results of a search of Defendant’s outbuilding; and (8) Defendant was not denied a fair trial due to cumulative error. View "State v. Sprague" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated indecent liberties with a child and two counts of aggravated criminal sodomy involving his three-year-old twin daughters. The bulk of the evidence at trial against Defendant was Defendant’s admissions to others, including law enforcement, that he had committed the offenses. Defendant received four life sentences. The court of appeals affirmed all four convictions. The Supreme Court (1) affirmed Defendant’s convictions for aggravated indecent liberties with a child and the consecutive life sentences imposed for them, holding, inter alia, that Defendant’s confessions concerning one victim were sufficiently truthworthy to establish the corpus delicti; but (2) reversed both aggravated criminal sodomy convictions, holding that the trial court improperly instructed the jury on alternative means of committing that crime without supporting evidence for each means presented to the jury, and the court of appeals erred in applying the invited error doctrine to preserve those convictions. View "State v. Dern" on Justia Law

The State filed a complaint charging Defendant with one count of felony theft by deception. Both parties submitted instructions to the trial court setting out the elements of theft by unauthorized control. The jury found Defendant guilty of felony theft. The Court of Appeals affirmed, concluding that the conviction was the result of error invited by both parties. The Supreme Court reversed, holding (1) the parties never raised on appeal the discrepancy between the charge and the instruction, and therefore, the case must be analyzed on the terms that the parties argued it, as a matter of whether the evidence sufficed to sustain a conviction for theft by deception; and (2) considered from a sufficiency of the evidence perspective, the evidence was insufficient to convict Defendant of theft by deception. View "State v. Laborde" on Justia Law

The State charged Appellant with multiple offenses related to the murders of six women. The murders constituted parts of a common scheme or course of conduct. Appellant was sentenced to death for his convictions for two counts of capital murder. On appeal, Appellant raised nineteen general claims of reversible error covering the entire trial proceedings, as well as a variety of sub-claims. The Supreme Court (1) affirmed Appellant’s capital murder conviction charged in Count II; (2) reversed Appellant’s capital murder conviction charged in Count III and his first-degree murder conviction charged in Count V as unconstitutionally multiplicitous with the capital murder conviction in Count II; (3) affirmed the remainder of Appellant’s convictions; (4) affirmed Appellant’s sentence of death under his capital murder conviction in Count II; and (5) vacated the portion of Appellant’s sentence designating certain of his crimes sexually motivated and remanded for a correction of the journal entry. View "State v. Robinson" on Justia Law

After a jury trial, Defendant was convicted of one count of aggravated robbery. The district court sentenced Defendant to 172 months in prison. Defendant appealed, challenging his sentence. The Supreme Court vacated Defendant’s sentence and remanded for resentencing, holding (1) the district court did not err by classifying two of Defendant’s pre-Kansas Sentencing Guidelines Act (KSGA) convictions for attempted rape and aggravated burglary as person felonies; but (2) the classification as a person felony of Defendant’s third pre-KSA conviction for burglary was unconstitutional because it was based on a fact that was never proven to a jury beyond a reasonable doubt. View "State v. Luarks" on Justia Law

After a jury trial, Defendant was convicted of aggravated criminal sodomy, aggravated indecent liberties with a child, and three counts of criminal sodomy for the sexual abuse of his daughter. The district court imposed a hard twenty-five sentence for the aggravated criminal sodomy count and an additional 118 months’ imprisonment for the remaining counts. The Supreme Court remanded the case to the district court for a State v. Van Cleave hearing to determine whether Defendant was denied his Sixth Amendment right to counsel, either because trial counsel was not constitutionally competent or was not constitutionally conflict-free. View "State v. Moyer" on Justia Law

After a second jury trial, Defendant was once again convicted of felony murder and the underlying felony of criminal discharge of a firearm at an occupied dwelling. The Supreme Court affirmed Defendant’s convictions, holding (1) the district court did not err in failing to give lesser included offense instructions to the felony-murder charge; (2) the prosecutor made a misstatement of the law during closing argument, but the misconduct did not deprive Defendant of a fair trial; (3) the district court did not commit judicial misconduct in giving an instruction warning the jury against considering any information outside of the evidence presented at trial; and (4) Defendant’s Sixth and Fourteenth Amendment rights were not violated because the State did not prove his prior convictions beyond a reasonable doubt when imposing an enhanced sentence. View "State v. Tahah" on Justia Law

After a jury trial, Defendant was convicted of four counts of aggravated assault of a law enforcement officer committed with a deadly weapon. At trial, Defendant presented evidence showing that he was heavily intoxicated when he fired his weapon. Defendant argued on appeal that the district court erred by instructing the jury that voluntary intoxication was not a defense to aggravated assault to a law enforcement officer. The Court of Appeals reversed, concluding that the district court committed clear error in instructing the jury that voluntary intoxication was not a defense to the charged crimes because it relieved the State of its burden of proving that Defendant acted knowingly, the mental state required to prove assault. The Supreme Court reversed, holding that the district court’s instruction was not clearly erroneous because aggravated assault of a law enforcement officer committed with a deadly weapon is a general intent crime, and voluntary intoxication is not a defense to the prosecution of a general intent crime. View "State v. Kershaw" on Justia Law