Justia Kansas Supreme Court Opinion Summaries

In 1993, Defendant was convicted of the second-degree murder of his wife. Defendant received a sentence of fifteen years to life imprisonment. In 2009, Defendant filed a pro se petition for postconviction DNA testing under Kan. Stat. Ann. 21-2512. The postconviction court summarily denied the petition because the statute limited the availability of such testing to cases involving convictions of first-degree murder or of rape. The Supreme Court extended section 21-2512 to Defendant and other similarly situated individuals under the authority of the Equal Protection Clause. While his appeal was still pending, Defendant was released from prison and placed on parole. When the district court took up his DNA testing petition on remand, the judge denied it, ruling that the legislature did not intend to allow consideration of section 21-2512 petitions from individuals on conditional release. The Supreme Court reversed, holding that because Defendant was in prison at the time his section 21-2512 petition for DNA testing was filed, he was “in state custody” at the relevant time. Remanded. View "State v. Cheeks" on Justia Law

Defendant pleaded guilty to two counts of felony murder based on the deaths of his girlfriend and his girlfriend’s two-year-old niece. At the plea hearing, Defendant admitted he intentionally set fire to an apartment, killing the victims. The district court sentenced Defendant to two consecutive life sentences with a mandatory minimum of twenty years each. Defendant appealed the consecutive nature of his sentences. The Supreme Court affirmed, holding that the district court made an adequate record of its decision to order Defendant to serve the sentences consecutively and did not abuse its discretion in sentencing Defendant to two consecutive life sentences. View "State v. Horn" on Justia Law

After a jury trial, Defendant was convicted of attempted first-degree murder. The court of appeals affirmed. Both the State and Defendant appealed. The Supreme Court affirmed Defendant conviction but vacated his sentence, holding (1) Defendant’s Sixth Amendment right to a public trial did not attach to the questioning of the victim, and therefore, the closure of the courtroom for a hearing to determine whether the witness would testify did not violate Defendant’s right to a public trial; (2) trial counsel did not provide ineffective assistance; and (3) due to problems in the district judge’s decision to grant a downward durational departure, the case must be remanded for resentencing. View "State v. Reed" on Justia Law

An infant died from respiratory failure after becoming trapped between the mattress and footboard of an adult bed at the home of Defendant, his daycare provider. After a jury trial, Defendant was convicted of involuntary manslaughter and aggravated endangering a trial. The court of appeals affirmed Defendant’s convictions. The Supreme Court affirmed, holding (1) the district court properly denied Defendant’s pretrial motion to dismiss because the motion was untimely; (2) sufficient evidence supported Defendant’s convictions; (3) the district court’s instructions to the jury on two means of committing involuntary manslaughter did not violate Defendant’s right to a unanimous jury verdict; (4) the district court did not clearly err by declining to define “imminence” for the jury; (5) the district court did not err in refusing to issue Defendant’s limiting instruction regarding the evidentiary value of a state regulation; and (6) the district court’s response to the deliberating jury’s question was harmless error. View "State v. Bolze-Sann" on Justia Law

After a jury trial, Defendant was found guilty of possession of marijuana, possession of drug paraphernalia, possession of cocaine, and fleeing and eluding a police officer while committing five or more moving violations. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the jury instructions, read together with an answer provided to a question posed by the jury, were sufficient for the jury to understand the foundation for a conviction; (2) Defendant’s defense was not prejudiced by the State’s failure to disclose in advance of the trial the existence of a videotape of vehicle pursuit; and (3) an instruction on drug paraphernalia did not invade the province of the jury by informing the jury that it must find that Defendant was using a scale as an accessory to illegal drug distribution. View "State v. Sisson" on Justia Law

Defendant pleaded guilty to aggravated robbery. The plea agreement obligated the State to join in Defendant’s request for a downward dispositional departure to probation. After a hearing, the sentencing judge denied Defendant’s dispositional departure motion. Defendant appealed, arguing that the prosecutor violated the plea agreement by not joining in her downward departure motion. The court of appeals affirmed, holding that the prosecutor did not violate the plea agreement, as that the prosecutor’s comments were adequate to fulfill the agreement’s requirement for the State to recommend probation. The Supreme Court reversed, holding (1) the prosecutor had an affirmative duty arising from the plea agreement to recommend a particular sentence; and (2) the State breached its plea agreement with Defendant. View "State v. Jones" on Justia Law

After a jury trial, Defendant was convicted of rape, aggravated sodomy, and criminal restraint. The court of appeals reversed Defendant’s criminal restraint conviction as multiplicitous with his rape conviction but otherwise affirmed. Defendant later filed a motion for new trial that was based on the results of postconviction DNA testing. Ultimately, the district court denied Defendant’s motion for new trial, concluding that the new DNA evidence was unlikely to have yielded a different outcome at trial. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court (1) made sufficient findings of fact and conclusions of law to facilitate meaningful appellate review; and (2) did not err in denying Defendant’s motion for new trial because no reasonable probability existed that the new DNA evidence would result in a different outcome at trial. View "State v. Rodriguez" on Justia Law

This appeal concerned two unrelated cases. In the first case, Defendant pleaded guilty to burglary and misdemeanor theft. Defendant was eighteen years old when the crimes were committed. In the second case, Defendant pleaded guilty to aggravated indecent liberties with a child. Defendant was seventeen years old when the crime was committed. The district court authorized Defendant to be prosecuted as an adult. The cases were consolidated for pleas and sentencings. The district court sentenced Defendant to terms of imprisonment and to a lifetime of supervision once he was released from prison. The court of appeals affirmed, concluding that mandatory lifetime postrelease supervision for juveniles convicted of aggravated indecent liberties does not categorically constitute cruel and unusual punishment under the Eighth Amendment. The Supreme Court reversed, holding that mandatory lifetime postrelease supervision for juveniles who have committed and are later convicted of aggravated indecent liberties with a child is categorically unconstitutional. View "State v. Dull" on Justia Law

Defendant pled guilty to first-degree felony murder and aggravated battery. The plea agreement contained a provision stating that the parties agreed to recommend that Defendant serve his sentence at Larned State Hospital. During sentencing, confusion surfaced regarding the precise nature of the plea agreement on the subject of Defendant’s placement at Larned. The district court pronounced Defendant’s sentence with the recommendation that “the Secretary of Corrections consider very strongly having [Defendant] transferred to Larned State Hospital.” Defendant appealed, arguing that the agreement was ambiguous and should have been interpreted to recommend that the State ask the court to commit Defendant to Larned in lieu of sentencing. The Supreme Court declined to reach the merits of Defendant’s claim because he failed to preserve it for appellate review with a contemporaneous objection. View "State v. Godfrey" on Justia Law

Defendant pled guilty to felony theft. The district court sentenced Defendant to sixteen months in prison after classifying Defendant’s prior 1992 in-state juvenile adjudication for burglary as a person felony, resulting in Defendant having a criminal history score of A and placing him in the A-9 grid box of the Kansas Sentencing Guidelines. The Court of Appeals vacated Defendant’s sentence and remanded for resentencing, concluding that the district court violated Defendant’s constitutional rights as described in Descamps v. United States and Apprendi v. New Jersey. Both the State and Defendant appealed. The Supreme Court affirmed, holding (1) Defendant’s legal challenge to the classification of his prior burglary adjudication can be raised for the first time on appeal; (2) classifying Defendant’s prior burglary adjudication as a person felony violates Defendant’s constitutional rights as described under Descamps and Apprendi; and (3) neither the legal reasoning nor holding in State v. Murdock has any applicability to the classification issue raised in this case. View "State v. Dickey" on Justia Law