Justia Kansas Supreme Court Opinion Summaries

In 2004, Defendant was convicted of rape, aggravated criminal sodomy, and aggravated indecent liberties. The Supreme Court reversed the convictions, concluding that the district judge had erred by admitting evidence of Defendant's sexual abuse of two victims other than the one making the allegations underlying this case pursuant to Kan. Stat. Ann. 60-455. The legislature responded to the Court's decision by amending section 60-455. At Defendant's retrial, the district judge apparently applied the amended statute to admit the same disputed evidence. Defendant was against convicted. The Supreme Court affirmed, holding (1) the application of the amended version of section 60-455 at Defendant's retrial did not violate the federal constitutional prohibition on ex post facto laws; and (2) the district judge erred by admitting evidence of Defendant's uncharged sexual abuse of two victims under the amended version of section 60-455, but reversal was not required because the evidence would come in as relevant to Defendant's propensity to abuse the victim in this case under the new section 60-455(d). View "State v. Prine" on Justia Law

After a trial, Defendant was convicted for an aggravated weapons violation. The court of appeals affirmed the conviction, determining that there were procedural bars precluding review of Defendant's case. Defendant appealed, contending that his statutory speedy trial rights were violated because he was not brought to trial within 180 days of his request to expedite his case under the Uniform Mandatory Disposition of Detainers Act (UMDDA), which provides an intrastate process for prisoners in Kansas penal or correctional institutions to request final disposition of other criminal charges pending in the state. The Supreme Court reversed Defendant's conviction and vacated his sentence, holding (1) the court of appeals erred in finding Defendant's UMDDA request was fatally deficient; (2) the district court erred in determining that the UMDDA was inapplicable to Defendant's pending charges; and (3) because Defendant properly initiated disposition of his other charges under the UMDDA, the State's failure to bring those charges to trial within 180 days deprived the district court of jurisdiction to try, convict, or sentence Defendant. View "State v. Burnett" on Justia Law

Defendant pled guilty to four crimes arising from the abuse of his girlfriend's nineteen-month-old son, resulting in the child's death. The district court ran Defendant's sentences for the four crimes, which included child abuse and felony murder, consecutive to one another. The Supreme Court affirmed Defendant's sentences, holding (1) the judge did not abuse his discretion in imposing consecutive sentences, as a reasonable person could agree with the judge's conclusion that consecutive sentences were appropriate; and (2) Defendant's sentence of 128 months' imprisonment for child abuse did not violate his constitutional rights as recognized in Apprendi v. New Jersey. View "State v. Baker" on Justia Law

Appellant was injured in the course of providing aid to a calf that he was escorting onto a neighbor's property. Appellant sued to recover medical damages from the neighbor (Appellee), claiming that Appellees were negligent in creating a dangerous condition on their property that presented an unreasonable risk of harm by leaving their gate open and by leaving a clothesline wire running across the ground. The district court granted summary judgment for Appellees, holding that Appellant was a trespasser on Appellees' property and they had breached no duty toward him. The court of appeals affirmed. The Supreme Court reversed, holding that the district court applied the incorrect standard for the duty of care in this case. Remanded for the submission of new arguments predicated on the proper duty. View "Wrinkle v. Norman" on Justia Law

The State charged Defendant with one count of cocaine possession after law enforcement officers arrested him on an outstanding warrant and discovered cocaine in his shoe. The district court granted Defendant's motion to suppress the cocaine, determining that the officers unlawfully detained Defendant before discovering the arrest warrant when they took his identification to run a warrants check, and that unlawful detention tainted the evidence found in the search. The court of appeals reversed. The Supreme Court reversed the court of appeals' decision and affirmed the district court's suppression ruling, holding (1) the officers unlawfully detained Defendant when they parked their patrol vehicle next to Defendant as he walked along a sidewalk, stood on either side of Defendant, and began asking Defendant questions, all without any reasonable suspicion of his involvement in any criminal activity; and (2) the officers' discovery of an outstanding arrest warrant during the unlawful detention did not purge the taint of Defendant's unlawful detention. View "State v. Williams" on Justia Law

The State charged Defendant with felony possession of marijuana. Defendant sought to suppress the marijuana as the fruit of an unlawful detention. The district court denied the motion and convicted Defendant as charged. The court of appeals affirmed the denial of Defendant's motion to suppress and Defendant's conviction. The Supreme Court reversed the court of appeals' judgment, the district court's suppression ruling, and Defendant's conviction, holding (1) the two law enforcement officers who arrested Defendant after what began as a voluntary encounter unlawfully detained Defendant when they retained his identification card and ran a warrants check without reasonable suspicion of his involvement in criminal activity; and (2) under the facts of this case, the officers' discovery of Defendant's outstanding arrest warrant did not sufficiently purge the taint of his unlawful detention. Remanded. View "State v. Moralez" on Justia Law

After a jury trial, Defendant was charged with and convicted of two counts of felony theft based on his admission that he grabbed a bank bag and a purse from a counter in a restaurant and fled with the stolen items. Defendant appealed, arguing that the two theft convictions violated federal and state constitutional prohibitions against double jeopardy because one of his two felony theft convictions was multiplicitous. The Supreme Court (1) reversed one of Defendant's theft convictions as multiplicitous, holding that, under the State v. Schoonover analysis, there was only one unit of prosecution under the theft statute, and the second conviction was multiplicitous; and (2) affirmed the use of criminal history in Defendant's sentence. Remanded. View "State v. Hood" on Justia Law

After a jury trial, Defendant was convicted of one count of rape of a child under the age of fourteen and sentenced to a lifetime sentence with a mandatory minimum of twenty-five years. The Supreme Court affirmed the conviction, holding (1) Defendant was not denied his statutory right to a unanimous verdict because the jury instruction did not present alternative means of committing the crime of rape requiring the State to present sufficient evidence of each means; (2) the trial court did not err in admitting into evidence Defendant's statement to law enforcement officers, as substantial competent evidence support the trial court's finding that the statement was voluntarily made; and (3) Defendant's argument that the trial court erred in the admission of certain evidence was not preserved for appeal. The Court, however, vacated Defendant's sentence and remanded for resentencing, holding that the sentencing judge abused his discretion by applying the wrong legal standard when denying Defendant's motion for departure from the statutory sentence, and this error was not harmless. View "State v. Randolph" on Justia Law

After a jury trial, Defendant was convicted of capital murder and rape and sentenced to a life sentence without parole for the murder conviction. Defendant appealed, arguing (1) the district court erred in allowing numerous photographs into evidence and by failing to instruct the jury on felony murder as a lesser included offense of capital murder, and (2) due to prosecutorial misconduct, he was denied a fair trial. The Supreme Court affirmed, holding (1) the district court acted within its discretion in admitting the disputed photographs into evidence at Defendant's trial; (2) the district court's failure to instruct the jury sua sponte on felony murder did not constitute clear error; and (3) the prosecutor did not commit misconduct during his closing argument. View "State v. Mireles" on Justia Law

Defendant was convicted of driving under the influence of alcohol (DUI). Defendant appealed, contending (1) the trial court erred in admitting certain evidence she claimed portrayed her as a bad mother and of low moral character; (2) the prosecutor engaged in misconduct by commenting in closing statements regarding the aforementioned evidence; and (3) the prosecution violated Kan. Stat. Ann. 60-447(a) which prohibits proof of a character trait by specific conduct. The court of appeals affirmed. The Supreme Court affirmed, holding (1) several of Defendant's arguments failed because Defendant failed to make specific and timely objections to the testimony she challenged on appeal; (2) the court of appeals did not err in its determination that the trial court's erroneous admission of testimony regarding Defendant's child visitation arrangements was harmless and the prosecutor's unanswered question regarding whether the children were in "good shape" when they were returned to their father was harmless; and (3) the court of appeals correctly held that Defendant failed to preserve her last argument regarding the alleged violation of section 60-447 for appeal. View "State v. Huffmier" on Justia Law