Justia Kansas Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of voluntary manslaughter and sentenced to 216 months’ imprisonment. The court of appeals affirmed on direct appeal. Defendant subsequently filed the present pro se motion for postconviction relief under Kan. Stat. Ann. 60-1507, alleging that his trial counsel was ineffective in three distinct ways. The district court denied the motion. The court of appeals affirmed. The Supreme Court reversed, holding that the district court erred by denying Defendant’s 60-1507 motion without an evidentiary hearing, as the motion, files, and records failed to show conclusively that Defendant was not entitled to relief. Remanded for an evidentiary hearing regarding Defendant’s allegations. View "Sola-Morales v. State" on Justia Law

After a jury trial, Defendant was convicted of attempted aggravated interference with parental custody and disorderly conduct. The court of appeals found several trial errors, including two instances of prosecutorial misconduct and three jury instruction errors, but concluded that the errors did not deprive Defendant of a fair trial. The Supreme Court reversed Defendant’s conviction for attempted aggravated interference with parental custody and affirmed her conviction for disorderly conduct, holding (1) two of the trial errors, both of which related to Defendant’s defense of ignorance or mistake, warranted the reversal of Defendant’s conviction for attempted aggravated interference with parental custody; and (2) the prejudice Defendant suffered as a result of these errors did not taint her conviction for disorderly conduct, nor did any other claimed errors. View "State v. Ortega" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, aggravated kidnapping, and aggravated robbery. After the sentencing judge found by a preponderance of the evidence the existence of four aggravating factors, Defendant received a hard fifty life sentence for the first-degree murder conviction. Defendant appealed, raising nine issues challenging his convictions and two challenging his sentences. The Supreme Court (1) affirmed Defendant’s convictions, thus rejecting Defendant’s claims of reversible error; and (2) vacated Defendant’s sentence for first-degree murder, holding that Defendant’s Sixth Amendment right to a jury trial, as interpreted in Alleyne v. United States, was violated because the judge, rather than the jury, found the four aggravating factors existed and did so on a preponderance-of-the-evidence standard, rather than a beyond-a-reasonable-doubt standard.View "State v. Hilt" on Justia Law

After a jury trial, Defendant was convicted of aggravated indecent liberties with a child. The Supreme Court reversed in part, holding that the trial court denied Defendant his right under the Sixth Amendment to have the effective assistance of counsel at a critical stage of the criminal proceedings against him when the court denied Defendant’s pro se motions for a new trial without first appointing new conflict-free counsel to assist Defendant in arguing the motions. Remanded for appointment of new counsel and instructions to hold a new holding on Defendant’s pro se motions for new trial.View "State v. Sharkey" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and criminal discharge of a firearm at an occupied building. The sentencing court sentenced Appellant to a hard twenty-five life sentence for the murder conviction. The Supreme Court affirmed on appeal, holding (1) the district court did not err in instructing the jury; (2) sufficient evidence supported the murder conviction; (3) the district court did not abuse its discretion in denying Appellant’s motion for a mistrial based on a juror’s statement mentioning gang involvement; and (4) because no errors were committed in this case, the cumulative error doctrine did not apply.View "State v. Betancourt" on Justia Law

In 1996, Appellant was convicted of one count of felony murder and one count of aggravated battery. As part of Appellant’s sentence, the sentencing court ordered Appellant to pay restitution in the amount of $119,900. No restitution was ever collected from Appellant. In 2009, a private corporation sent Appellant a notice that he had outstanding court fines and that he had to pay $150,904 immediately. Appellant filed a pro se motion requesting release from the restitution order based on dormancy. The district court denied the motion on the grounds that Appellant’s restitution was not yet due, reasoning that restitution cannot be enforced against a defendant while the defendant is incarcerated. The Supreme Court affirmed but on different grounds, holding (1) the district court did not enter an enforceable restitution judgment when it sentenced Appellant; and (2) because there was no pending judgment ordering Appellant to pay restitution, the district court had no jurisdiction to release an obligation on his part.View "State v. Alderson" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to life imprisonment without the possibility of parole for fifty years. The Supreme Court affirmed Defendant’s conviction but vacated his sentence, holding that Kansas’ hard fifty sentencing scheme violates the Sixth Amendment to the federal Constitution as interpreted in Alleyne v. United States and Ring v. Arizona because it permits a judge to find by a preponderance of the evidence the existence of one or more aggravating factors necessary to impose an increased mandatory minimum sentence, rather than requiring a jury to find the existence of the aggravating circumstances beyond a reasonable doubt. Remanded for resentencing.View "State v. Soto" on Justia Law

Appellant entered a plea of no contest to felony murder, attempted first-degree murder, aggravated robbery, and attempted aggravated robbery. Appellant docketed his appeal from his sentence and then filed a pro se motion to withdraw his plea. Thereafter, Appellant withdrew his motion because his case was pending on appeal. The Supreme Court subsequently vacated the sentence, and the district court resentenced Appellant. That same day, Appellant filed a renewed motion in district court seeking leave to withdraw the no contest plea. The district court denied the motion without an evidentiary hearing. The Supreme Court affirmed, holding (1) a defendant may move to withdraw a guilty plea after a cases is remanded from the appellate courts for resentencing; and (2) the district court did not abuse its discretion in finding that Appellant’s motion failed under either the good-cause or the manifest-injustice standard. View "State v. Fritz" on Justia Law

The State charged Defendant with possession of methamphetamine after law enforcement officers stopped Defendant’s vehicle based on a turn signal violation, searched the vehicle because they detected a very strong odor of alcohol coming from within the vehicle, and discovered methamphetamine during the search. Defendant filed a motion to suppress the fruits of the warrantless search. The district court denied the motion, concluding that the strong odor of alcohol emanating from within the vehicle established probable cause for the officers to search the vehicle for an open container of alcohol. The Supreme Court reversed, holding that the search was unlawful because the officers failed to acquire additional inculpatory facts relating to the crime being investigated before commencing their search of the vehicle.View "State v. Stevenson" on Justia Law

After a jury trial, Defendant was convicted of aggravated kidnapping, aggravated indecent liberties with a child, and criminal threat. The court of appeals affirmed on direct appeal. The Supreme Court accepted review to address Defendant’s claims that the prosecutor committed three separate acts of prosecutorial misconduct during trial. The court of appeals applied the prosecutorial misconduct standard as explained in State v. Tosh in rejecting Defendant’s contentions of prosecutorial misconduct. Before the Supreme Court Defendant argued that this traditional multi-prong test was flawed because it leaves open the possibility the misconduct affected the verdict. The Supreme Court affirmed, holding (1) Defendant’s criticism of the traditional prosecutorial misconduct standard was unwarranted; and (2) the court of appeals correctly found that there was no merit to two of Defendant’s misconduct claims, and the prosecutor’s misconduct in using a jigsaw puzzle analogy during voir dire and closing arguments did not deprive Defendant of a fair trial. View "State v. Crawford" on Justia Law