Justia Kansas Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of attempted first-degree murder. The court of appeals affirmed. Both the State and Defendant appealed. The Supreme Court affirmed Defendant conviction but vacated his sentence, holding (1) Defendant’s Sixth Amendment right to a public trial did not attach to the questioning of the victim, and therefore, the closure of the courtroom for a hearing to determine whether the witness would testify did not violate Defendant’s right to a public trial; (2) trial counsel did not provide ineffective assistance; and (3) due to problems in the district judge’s decision to grant a downward durational departure, the case must be remanded for resentencing. View "State v. Reed" on Justia Law

An infant died from respiratory failure after becoming trapped between the mattress and footboard of an adult bed at the home of Defendant, his daycare provider. After a jury trial, Defendant was convicted of involuntary manslaughter and aggravated endangering a trial. The court of appeals affirmed Defendant’s convictions. The Supreme Court affirmed, holding (1) the district court properly denied Defendant’s pretrial motion to dismiss because the motion was untimely; (2) sufficient evidence supported Defendant’s convictions; (3) the district court’s instructions to the jury on two means of committing involuntary manslaughter did not violate Defendant’s right to a unanimous jury verdict; (4) the district court did not clearly err by declining to define “imminence” for the jury; (5) the district court did not err in refusing to issue Defendant’s limiting instruction regarding the evidentiary value of a state regulation; and (6) the district court’s response to the deliberating jury’s question was harmless error. View "State v. Bolze-Sann" on Justia Law

Tenth-grader Jesus Rodriguez was injured while traveling to a soccer match in the bed of a pickup truck driven by a fellow student and teammate. Mutual of Omaha Insurance Company had issued a policy to the Kansas State High School Activities Association, which administered various extracurricular activities in the state. Rodriguez’s mother (Plaintiff) filed a claim with Mutual of Omaha. Mutual of Omaha denied the claim, reasoning that the travel during which Rodriguez was injured did not qualify as covered under the policy. Plaintiff sued the school district, Mutual of Omaha, and other defendants. The district judge held that Mutual of Omaha should be dismissed as a defendant in the case because Rodriguez’s travel was neither authorized by the school district nor subject to reimbursement, the two requirements for “covered travel” under the definition in the Mutual of Omaha policy. The court of appeals affirmed, holding that the travel involved in this case did not qualify as subject to reimbursement, and thus there was no coverage under the policy. The Supreme Court reversed, holding that the travel during which Rodriguez was injured was “authorized” and “subject to reimbursement,” and therefore, there was coverage under the policy language. View "Rodriguez v. United Sch. Dist. No. 500" on Justia Law

After a jury trial, Defendant was found guilty of possession of marijuana, possession of drug paraphernalia, possession of cocaine, and fleeing and eluding a police officer while committing five or more moving violations. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the jury instructions, read together with an answer provided to a question posed by the jury, were sufficient for the jury to understand the foundation for a conviction; (2) Defendant’s defense was not prejudiced by the State’s failure to disclose in advance of the trial the existence of a videotape of vehicle pursuit; and (3) an instruction on drug paraphernalia did not invade the province of the jury by informing the jury that it must find that Defendant was using a scale as an accessory to illegal drug distribution. View "State v. Sisson" on Justia Law

Defendant pleaded guilty to aggravated robbery. The plea agreement obligated the State to join in Defendant’s request for a downward dispositional departure to probation. After a hearing, the sentencing judge denied Defendant’s dispositional departure motion. Defendant appealed, arguing that the prosecutor violated the plea agreement by not joining in her downward departure motion. The court of appeals affirmed, holding that the prosecutor did not violate the plea agreement, as that the prosecutor’s comments were adequate to fulfill the agreement’s requirement for the State to recommend probation. The Supreme Court reversed, holding (1) the prosecutor had an affirmative duty arising from the plea agreement to recommend a particular sentence; and (2) the State breached its plea agreement with Defendant. View "State v. Jones" on Justia Law

Some of Plaintiffs’ cattle grazed on Defendants’ ranch. Plaintiffs sued Defendant alleging that Defendant breached numerous grazing contracts while Plaintiffs’ cattle were supposed to be calving, fattening, and breeding on Defendants’ pastures and that Defendant failed in his duty to adequately feed, supervise, and care for their cattle. The district court found that Defendant had breached the grazing contracts and awarded a total of $240,416 in damages. Defendant appealed. The court of appeals affirmed the damage award in most respects but remanded the award to the district court to correct three errors. The court also concluded that one Plaintiff, Steve Peterson, did not have standing and dismissed his claims. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the court of appeals correctly found that Peterson, who failed to present evidence that he personally owned any of the cattle in question, had no standing; (2) Defendant breached the grazing contract; and (3) the court of appeals correctly resolved the question of damages. View "Peterson v. Ferrell" on Justia Law

After a jury trial, Defendant was convicted of rape, aggravated sodomy, and criminal restraint. The court of appeals reversed Defendant’s criminal restraint conviction as multiplicitous with his rape conviction but otherwise affirmed. Defendant later filed a motion for new trial that was based on the results of postconviction DNA testing. Ultimately, the district court denied Defendant’s motion for new trial, concluding that the new DNA evidence was unlikely to have yielded a different outcome at trial. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court (1) made sufficient findings of fact and conclusions of law to facilitate meaningful appellate review; and (2) did not err in denying Defendant’s motion for new trial because no reasonable probability existed that the new DNA evidence would result in a different outcome at trial. View "State v. Rodriguez" on Justia Law

Plaintiff was injured from an automobile accident. A hospital toxicology report indicated that Plaintiff had a blood alcohol concentration of .25 two hours after the accident. Plaintiff submitted a claim to American Family Life Assurance Company of Columbus (AFLAC) pursuant to his hospital intensive care policy. AFLAC denied the claim under the policy’s intoxication exclusion, relying in part on the hospital toxicology report. Plaintiff filed suit seeking coverage under the policy. AFLAC moved to admit a copy of the toxicology report. Plaintiff objected, citing a lack of foundation. The district court sustained Plaintiff’s objection. After a trial, the district court concluded that Plaintiff was entitled to coverage under the policy because AFLAC failed to prove that Plaintiff’s accident was in consequence of his intoxication. The court of appeals reversed. The Supreme Court reversed the court of appeals and affirmed in part and reversed in part the district court, holding (1) the court of appeals erred in determining that AFLAC had satisfied the appropriate foundation requirements to admit the hospital’s toxicology report; (2) AFLAC failed to meet its burden of establishing that Plaintiff’s claim was excluded under the policy; and (3) the district court erred in determining that AFLAC’s denial of coverage was without just cause or excuse. View "Wiles v. Am. Family Life Assurance Co." on Justia Law

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