Justia Kansas Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of four counts of aggravated assault of a law enforcement officer committed with a deadly weapon. At trial, Defendant presented evidence showing that he was heavily intoxicated when he fired his weapon. Defendant argued on appeal that the district court erred by instructing the jury that voluntary intoxication was not a defense to aggravated assault to a law enforcement officer. The Court of Appeals reversed, concluding that the district court committed clear error in instructing the jury that voluntary intoxication was not a defense to the charged crimes because it relieved the State of its burden of proving that Defendant acted knowingly, the mental state required to prove assault. The Supreme Court reversed, holding that the district court’s instruction was not clearly erroneous because aggravated assault of a law enforcement officer committed with a deadly weapon is a general intent crime, and voluntary intoxication is not a defense to the prosecution of a general intent crime. View "State v. Kershaw" on Justia Law

After a jury trial, Defendant was found guilty of aggravated sexual battery. The district court sentenced Defendant to thirty-four months’ imprisonment. Defendant appealed, arguing that the district court erred by not instructing the jury on the lesser included offense of sexual battery and that the court erred in failing to appoint new, conflict-free counsel at a hearing on his pro se motion to dismiss counsel. The Supreme Court affirmed Defendant’s conviction, holding (1) Defendant failed to establish that the jury would have reached a different conclusion had the lesser included offense instruction regarding sexual battery been given; and (2) Defendant failed to establish that he was entitled to new counsel. View "State v. Pfannenstiel" on Justia Law

In the underlying “school finance” case, Shawnee Mission School District No. 512 (U.S.D. 512) filed a motion to intervene. Plaintiffs opposed U.S.D. 512’s entry into that litigation, and the State did not object. The district court panel denied the motion to intervene, concluding that the State adequately represented U.S.D. 512’s interests and that the motion to intervene was untimely. The Supreme Court affirmed, holding that the panel did not abuse its discretion in denying U.S.D. 512’s motion to intervene as a matter of right, as (1) U.S.D. 512’s interests were not adequately represented by the parties in this case; but (2) U.S.D. 512’s motion to intervene was untimely. View "Gannon v. State" on Justia Law

In State v. Ford, the Supreme Court held that a motion to correct an illegal sentence under Kan. Stat. Ann. 22-3504 is not an appropriate vehicle for challenging a conviction based upon an alleged violation of the competency to stand trial statute, Kan. Stat. Ann. 22-3302. In this case, Defendant filed a pro se motion to correct an illegal sentence a decade after he was convicted of felony murder and the sale of cocaine. In his motion, Defendant claimed, for the first time, that he had not been competent to stand trial, and therefore, the district court’s failure to sua sponte order a competency hearing and stay his prosecution rendered his convictions and sentences void for lack of jurisdiction. The district court summarily denied the motion. The Supreme Court affirmed, concluding that the holding in Ford controlled this case, and therefore, pursuant to Ford, Defendant may not utilize a motion to correct an illegal sentence to challenge the trial court’s alleged failure to comply with section 22-3302. View "State v. Donaldson" on Justia Law

In 2012, Kansas City Power & Light Company (KCPL) condemned a power line easement bisected to tracts of land owned by the trusts for Daniel and Evelyn Strong. The jury awarded the Strongs $1,922,559 in compensation for the taking. Earlier, court-appointed appraisers had awarded the Strongs $96,465 in damages. The Supreme Court affirmed the jury award and the judgment of the district court, holding (1) the district court did not err in denying KCPL’s motions to exclude or strike the expert testimony evidence offered by the Strongs; (2) the district court did not err in permitting the Strongs’ experts to testify pursuant to a common-law “development approach”; and (3) the district court did not err in admitting evidence regarding a 2004 option contract the Strongs entered into with a developer. View "Kansas City Power & Light Co. v. Strong" on Justia Law

After a jury trial, Defendant was convicted of premeditated first-degree murder and other crimes. Defendant was sentenced to life imprisonment with a mandatory term of fifty years for the first-degree murder conviction. The Supreme Court affirmed Defendant’s convictions, holding (1) the district court did not err by denying Defendant’s motion for a mistrial based on a potential juror’s statements; (2) Defendant did not preserve his argument that the district court erred in denying his motion to suppress an eyewitness identification; (3) the district court did err by denying Defendant’s motion for mistrial and his motion for a new trial based on the eyewitness’ changed testimony at trial; (4) the district court did not abuse its discretion in admitting a weapon and the results of scientific testing conducted on it despite any deficiency in the chain of custody; and (5) the district court’s instruction to the jury to consider the degree of certainty demonstrated by the eyewitness when identifying Defendant was not clearly erroneous. The Court, however, vacated Defendant’s hard fifty life sentence and remanded the case for resentencing, holding that Defendant’s sentence was imposed in violation of his constitutional right to a jury trial, and the error was not harmless. View "State v. Moore" on Justia Law

Plaintiffs, who were required to pay fees to a State agency in order to practice their trade or transact business in Kansas, brought suit challenging a 2009 appropriations bill that directed the transfer of moneys into the State General Fund from various State agency fee fund accounts into which Plaintiffs had paid fees. Plaintiffs sought a finding that the legislation directing the fee fund transfers was unconstitutional. The district court dismissed the suit, ruling (1) Plaintiffs did not have standing to sue because the moneys were taken from the agencies and not from the individuals that paid fees into the agencies’ accounts; and (2) Plaintiffs’ complaints were required to be addressed under the Kansas Judicial Review Act (KJRA). The Court of Appeals reversed, concluding (1) Plaintiffs had standing because they had been uniquely damaged by the transfer of funds; and (2) Plaintiffs were not required to bring their claims under the KJRA because the agencies had no authority under the KJRA to grant the relief sought. The Supreme Court affirmed, holding (1) Plaintiffs have suffered a cognizable injury, which injury is fairly traceable to the challenged conduct; and (2) the issue in this case does not present a nonjusticiable political question. Remanded. View "Kansas Bldg. Indus. Workers Comp. Fund v. State" on Justia Law

After a second mistrial, Appellant was convicted of sex-related crimes. The convictions were affirmed on appeal. Appellant later filed a Kan. Stat. Ann. 60-1507 motion alleging ineffective assistance of both trial counsel and direct appeal counsel. The district court ultimately granted the motion and reversed the conviction. Thereafter, pursuant to a plea agreement, Appellant entered an Alford plea on different charges. In exchange, the State dropped the original charges. Between entering into the plea agreement and sentencing, Appellant filed this legal malpractice action against trial and appellate counsel and the Board of Indigents’ Defense Services (BIDS). The district court ruled that BIDS lacked the capacity to be sued, that Appellant’s Alford plea foreclosed the relief sought, and that Appellant’s claim was time barred. The Court of Appeal agreed with the district court with the exception of the statute of limitations issue, ruling that Appellant’s claim was timely filed. The Supreme Court affirmed in part and reversed in part, holding (1) the Court of Appeals correctly found that BIDS is not subject to suit in a legal malpractice action; (2) Defendant may pursue this legal malpractice claim without first demonstrating actual innocence of the charged crimes; and (3) this suit was timely filed under the applicable statute of limitations. View "Mashaney v. Bd. of Indigents' Defense Servs." on Justia Law

After a joint trial with his co-defendant, Defendant was convicted of one count of premeditated first-degree murder and other crimes and sentenced to life with a minimum term of fifty years. The Supreme Court affirmed the convictions but vacated the hard fifty life sentence, holding (1) the district court did not err by denying Defendant’s motion for a mistrial based on a potential juror’s statements; (2) the district court did err by denying Defendant’s motion for mistrial based on a witness’ testimony; (3) the district court did not err in denying Defendant’s motion for a new trial based on newly discovered evidence; (4) the district court did not err in denying Defendant’s motion to sever his trial from his co-defendant’s trial; (5) the reasonable doubt instruction given in this case was not clearly erroneous; but (6) Defendant’s sentence was imposed in violation of his constitutional right to a jury trial, and the error was not harmless. Remanded for resentencing. View "State v. Warren" on Justia Law

After a jury trial, Defendant was convicted of possession of methamphetamine and possession of drug paraphernalia. The Court of Appeals affirmed Defendant’s convictions. After review was granted by the Supreme Court, Defendant filed a motion to correct an illegal sentence, arguing that the district court erred in classifying his 1993 Kansas convictions for attempted aggravated robbery and aggravated robbery as person felonies, resulting in a longer sentence. The Supreme Court affirmed the convictions and sentence, holding (1) the State presented sufficient evidence to support the convictions; (2) the trial court did not err in instructing the jury on the definition of drug paraphernalia; and (3) Defendant’s 1993 Kansas convictions must be classified as person offenses based on the classification in effect for those crimes when Defendant committed his current crimes of conviction. View "State v. Keel" on Justia Law