Justia Kansas Supreme Court Opinion Summaries

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

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