Justia Kansas Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of felony murder, three counts of attempted aggravated robbery, and one count of aggravated burglary. The district court imposed a life sentence for the felony-murder conviction and a 153-month sentence consecutive to the life sentence for the remaining convictions. The Supreme Court affirmed the convictions but vacated the 153-month sentence and remanded for resentencing, holding (1) the State presented sufficient evidence to convict Defendant of the felony murder; (2) the district court’s jury instruction on felony murder was not erroneous; but (3) the district court violated the “double-rule” of Kan. Stat. Ann. 21-6819(b)(4) when it imposed the 153-month sentence because the sentence was more than double the amount of prison time Defendant received for his primary crime of attempted aggravated robbery. View "State v. McClelland" on Justia Law

Law enforcement officers employed by the City of Prairie Village set up a controlled drug buy from Defendant to occur in the City of Leawood. As a result of the controlled buy, the State charged Defendant with felony drug charges. Defendant moved to suppress the drugs and an audio recording of the controlled buy, arguing that the Prairie Village officers had obtained that evidence while exercising their police powers outside of their jurisdiction as authorized under Kan. Stat. Ann. 22-2401(a)(2). The district court granted the motion and suppressed the evidence. The court of appeals reversed, finding that the Prairie Village officers had jurisdiction in Leawood based on a provision in section 22-2401(a)(2)(b) allowing municipal officers to exceed their jurisdictional boundaries when another jurisdiction requests assistance. The Supreme Court affirmed on different grounds, holding (1) the statutory limitations on the jurisdiction of city officers was put in place to protect the local autonomy of neighboring cities and counties, rather than to create an individual right; and (2) consequently, the suppression of any evidence obtained during a city officer’s unauthorized exercise of police power outside the officer’s employing city will generally not be required. View "State v. Vrabel" on Justia Law

In 2009, E.J.D. entered a plea of no contest to battery on juvenile detention officers. The court determined that the proceedings should be designated as an extended-jurisdiction juvenile prosecution and sentenced E.J.D. to a term in a juvenile correction facility and to an adult criminal sentence. The court stayed the adult criminal sentence on the condition that E.J.D. not violate the provisions of the juvenile sentence and on the condition that he not commit a new offense. The State subsequently moved to revoke the stay of execution of the adult sentence based on numerous disciplinary violations committed by E.J.D. Thereafter, E.J.D. moved for a lesser sentence and a durational departure from his sentence. The district court denied E.J.D.’s motion and ordered him committed to the custody of the Department of Corrections. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the statutory scheme does not allow modification of an adult sentence after a determination that a juvenile has violated the terms and conditions of an extended jurisdiction juvenile prosecution; and (2) the court of appeals correctly determined that the evidence supported the district court’s decision to revoke the stay of execution of the adult sentence. View "In re E.J.D." on Justia Law

After a jury trial, Defendant was convicted of six drug offenses. The court of appeals affirmed in part and reversed in part, resulting in a reversal of one of Defendant’s convictions and the vacating of one of his sentences. Those issues were not before the Supreme Court for review. On appeal, Defendant sought the Court’s review of that portion of the court of appeals’ decision that was adverse to him. The Supreme Court affirmed, holding that the district court did not err in (1) denying Defendant’s motion to suppress evidence obtained from the warrantless search of his vehicle; (2) convicting Defendant for the separate offenses of possessing red phosphorous and iodine and possessing drug paraphernalia with intent to manufacture, as those convictions were not multiplicitous; and (3) using Defendant’s prior convictions to enhance his sentence. View "State v. Overman" on Justia Law

After a jury trial, Defendant was convicted of premeditated first-degree murder. The Supreme Court affirmed, holding (1) Defendant was not entitled to an instruction on self-defense; (2) the district court did not commit clear error by failing to instruct on second-degree intentional murder; (3) the prosecutor committed misconduct during closing arguments by vouching for the credibility of some witnesses, discussing facts not in evidence, and disparaging the defense, but the statements did not deprive Defendant of a fair trial; (4) the district court did not err in excluding evidence suggesting that a third party might have had a motive to commit the murder; (5) Defendant did not preserve his argument that the district court violated his confrontation rights by limiting cross-examination of a state witness; and (6) the presumed instructional error and the instances of prosecutorial misconduct did not cumulatively deny Defendant a fair trial. View "State v. Knox" on Justia Law

Plaintiff, an inmate in the custody of the Kansas Department of Corrections (DOC), took advantage of a statutorily created inmate trust fund to place money in the custody of the DOC for his use while serving his sentence. Plaintiff filed suit in Leavenworth District Court pursuant to the Kansas Uniform Trust Code (KUTC) alleging that Defendants were in breach of trust by charging various fees against the balance held in his inmate fund. Defendants successfully moved to transfer venue to Norton District Court. Plaintiff filed a motion to transfer venue back to Leavenworth District court, claiming that because the inmate trust fund was administered at the Lansing Correctional Facility in Leavenworth County, his claims under the KUTC could only be brought in Leavenworth District Court pursuant to Kan. Stat. Ann. 58a-204. The Norton District Court denied Plaintiff’s motion and granted summary judgment to Defendants on all of Plaintiff’s claims. The Court of Appeals affirmed, concluding that Plaintiff could have filed his suit in Norton County under Kan. Stat. Ann. 60-602(2). The Supreme Court reversed, holding (1) the inmate trust is a trust subject to the KUTC; and (2) the KUTC establishes exclusive venue in the county were the inmate trust fund is administered - i.e., in Leavenworth County. View "Matson v. Kan. Dep’t of Corr." on Justia Law

While fleeing the police during a high-speed chase, Defendant collided with another vehicle, killing both occupants. After a jury trial, Defendant was convicted of two counts of first-degree felony murder and one count of fleeing or attempting to elude a police officer. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by urging defense counsel to complete voir dire or setting a time limitation on the second day; (2) the district court’s remark in the jury’s presence about the time defense counsel was taking during voir dire was not improper or prejudicial; (3) the district court did not err in refusing to change venue; (4) the prosecutor made a misstatement as to the process for considering lesser included offenses, but the misstatement did not so prejudice the jury as to deny Defendant a fair trial; and (5) the State properly charged felony murder rather than involuntary manslaughter while driving under the influence. View "State v. Hudgins" on Justia Law

Defendant pled guilty to one count of first-degree murder. Just over one year later, the clerk of the district court received a pro se motion for postconviction relief pursuant to Kan. Stat. Ann. 60-1507, in which Defendant alleged that he received ineffective assistance of counsel. Defendant filed his supporting memorandum less than one month later. The district court summarily denied the motion, concluding that Defendant had waived his right to file a section 60-1507 motion based on the purported ineffective assistance of counsel and that the motion was time-barred. The Court of Appeals affirmed but on different grounds, concluding that Defendant’s supporting memorandum should be treated as an attempted section 60-1507 amendment and that the amendment was time-barred. The Supreme Court reversed, holding (1) the district court erred by concluding that Defendant waived his right to file a section 60-1507 motion alleging ineffective assistance of counsel; (2) the district court erred by concluding that Defendant failed to file his section 60-1507 motion within the one-year time limitation in Kan. Stat. Ann. 60-1507(f)(1); and (3) the Court of Appeals erred in affirming the district court’s dismissal after treating the supporting memorandum as an untimely amendment. Remanded. View "Wahl v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder and arson. The district court imposed a hard fifty life sentence after finding that Defendant committed the murder in an especially heinous, atrocious, or cruel manner. The Supreme Court affirmed the convictions but vacated the sentence and remanded for resentencing, holding (1) the district court did not err in denying Defendant’s request for a jury instruction on self-defense; (2) any error in denying Defendant’s request for a voluntary manslaughter instruction based on a theory of imperfect self-defense was harmless; (3) the district court erred in admitting Defendant’s recorded confession when Defendant unambiguously invoked his right to have counsel present during custodial interrogation, but the error was harmless; and (4) Defendant’s hard fifty sentence was unconstitutional under Alleyne v. United States because the district court denied Defendant the right to have a jury decide beyond a reasonable doubt all of the facts that may increase the penalty for first-degree murder. View "State v. Salary" on Justia Law

After a jury trial, Defendant was found guilty of felony murder and criminal discharge of a firearm at an occupied building. During trial, the jury received instructions on second-degree unintentional murder and involuntary manslaughter as lesser included offenses of felony murder. Defendant appealed, arguing that the prosecutor misstated the law - thus, committing misconduct - when he told the jurors during closing arguments that they were to consider Defendant’s guilt for the lesser included crimes only after finding him not guilty of felony murder. The Supreme Court affirmed, holding (1) the prosecutor’s statement was erroneous because it suggested to the jury that it must unanimously acquit him of felony murder before considering his guilt for the lesser included crimes; but (2) because the prosecutor also recited the correct legal standard during closing arguments and the overwhelming evidence established Defendant’s guilt for felony murder, the prosecutor’s erroneous statement did not constitute reversible misconduct. View "State v. Parker" on Justia Law