Justia Kansas Supreme Court Opinion Summaries

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

Defendant was convicted of driving while under the influence of alcohol and speeding. Defendant appealed both convictions and sought a trial de novo in district court, arguing that the evidence was the product of an illegal traffic stop. Specifically, Defendant argued that the officer who initiated the traffic stop did not have reasonable suspicion for the stop because the officer was mistaken about the applicable speed limit where a traffic sign normally posting the limit had been knocked to the ground. The Supreme Court affirmed, holding that the officer made a mistake of fact about the speed limit, but the mistake was objectively reasonable. View "City of Atwood v. Pianalto" on Justia Law

The Kansas Highway Patrol (KHP) arrested an indigent criminal offender. The offender sustained injuries during the arrest and was driven to the emergency room at Kansas University Medical Center, where he received treatment. The next day, the offender was transported to the Wyandotte County Jail, where he awaited trial on felony charges. The University of Kansas Hospital Authority demanded payment from both the Unified Government of Wyandotte County/Kansas, City Kansas (County) and KHP. When both entities refused to pay for the offender’s expenses, the Hospital Authority filed suit against both the County and KHP. The district court and Court of Appeals concluded that KHP was liable for the offender’s medical expenses. The Supreme Court affirmed, holding that the offender was under arrest and in KHP’s custody at the time he was taken to the hospital for treatment, and, based on that custody, KHP was liable for the offender’s reasonable medical expenses. View "Univ. of Kan. Hosp. Auth. v. Bd. of County Comm'rs" on Justia Law

Defendant received two consecutive twelve-month probation terms. As a result of a violation that occurred during the first twelve months, the district court revoked both of Defendant’s probation terms. The Court of Appeals affirmed. Earlier, the Supreme Court had effectively compelled the Court of Appeals to address the merits of Defendant’s appeal by granting a petition for review on the Court of Appeals’ dismissal of Defendant’s appeal and then summarily reversing and remanding the case. Here, the Supreme Court concluded that the Court of Appeals had it right in the first place. The Supreme Court vacated the decision of the Court of Appeals and dismissed this appeal as moot because Defendant had already completed service of the prison terms underlying the consecutive probations. View "State v. Hilton" on Justia Law

After a jury trial, Defendant was convicted of aiding and abetting first-degree premeditated murder, possession of cocaine with intent to distribute, and possession of marijuana. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion for new trial based on the State’s failure to disclose a plea agreement with the codefendant, as the plea agreement would not have changed the course of the trial by making the codefendant available to testify at trial; and (2) the district court’s failure to give a second-degree murder jury instruction was not clearly erroneous. View "State v. Soto" on Justia Law

After a jury trial, Defendant was convicted of capital murder based on his premeditated intentional killing of his ex-girlfriend and their one-year-old son. Defendant appealed, arguing that the trial court erred in denying his motion to suppress incriminating statements he made during two separate interrogations by law enforcement officers. The Supreme Court reversed, holding (1) the interrogating officers refused to terminate the questioning when Defendant invoked his rights under Miranda v. Arizona; and (2) because the error was not harmless, the district court erred in denying the suppression of Defendant’s statements made after the Miranda violation. View "State v. Aguirre" on Justia Law

Pursuant to a plea agreement, Appellant pleaded guilty to one count of attempted indecent solicitation of a child. The district court sentenced Appellant to eighteen months’ probation, with an underlying ten-month prison term and lifetime postrelease supervision. Appellant appealed, contending that lifetime postrelease supervision was disproportionate as applied to him, constituting cruel and/or unusual punishment in violation Section 9 of the Kansas Constitution Bill of Rights and the Eighth Amendment to the federal Constitution. The Court of Appeals affirmed. The Supreme Court affirmed, holding (1) Appellant abandoned his Eighth Amendment challenge on appeal for failure to adequately brief the issue; and (2) Appellant’s lifetime postrelease supervision term does not constitute cruel or unusual punishment under Section 9 of the Bill of Rights. View "State v. Funk" on Justia Law

Defendant was convicted of possession of marijuana with the intent to distribute and related offenses. On appeal, Defendant argued that the warrantless search of his cell phone conducted as a search incident to arrest violated his rights under the Fourth Amendment to the U.S. Constitution. The Court of Appeals affirmed. The Supreme Court reversed, holding (1) the search of Defendant’s cell phone violated the Fourth Amendment because Defendant did not unequivocally, specifically, and freely give consent for the officer to search the text messages on his cell phone, and Defendant’s consensual responses were not free from duress or coercion; and (2) the unlawful search of Defendant’s cell phone was not harmless. View "State v. James" on Justia Law