Justia Kansas Supreme Court Opinion Summaries

In 1996, Kodi Thomas was convicted of attempted rape and aggravated burglary. A civil jury later declared Thomas to be a sexually violent predator under the Kansas Sexually Violent Predator Act subject to civil commitment. The court of appeals affirmed. Thomas appealed, arguing that the district court erred by permitting the State’s experts to testify about hearsay statements contained within his treatment records and by erroneously instructing the jury on the State’s burden of proof. The Supreme Court affirmed, holding (1) Thomas failed to preserve the hearsay issue for appeal; and (2) the instructional error was harmless. View "In re Care & Treatment of Thomas" on Justia Law

Defendant pleaded guilty to first-degree premeditated murder for killing his estranged wife. The district court sentenced Defendant to life imprisonment without parole for twenty-five years, ordered Defendant not to have any contact with the victim’s family, and imposed a restitution order requiring Defendant to pay attorney fees incurred by the victim’s mother in child in need of care (CINC) proceedings involving the couple’s children and a separate legal action finalizing her adoption of the children. Defendant appealed his sentence. The Supreme Court vacated the no-contact order and affirmed the restitution order, holding (1) in line with caselaw, the no-contact order should be vacated because it constituted an illegal sentence where it is a probation condition that cannot be imposed in conjunction with prison sentences; and (2) a sufficient causal link existed between Defendant’s unlawful conduct and the attorney fees for the CINC proceedings and adoption case, and the district court properly rejected the claim that any restitution plan was unworkable. View "State v. Alcala" on Justia Law

After a jury trial, Defendant was found guilty of felony murder, three counts of attempted aggravated robbery, and one count of aggravated burglary. The district court imposed a life sentence for the felony-murder conviction and a 153-month sentence consecutive to the life sentence for the remaining convictions. The Supreme Court affirmed the convictions but vacated the 153-month sentence and remanded for resentencing, holding (1) the State presented sufficient evidence to convict Defendant of the felony murder; (2) the district court’s jury instruction on felony murder was not erroneous; but (3) the district court violated the “double-rule” of Kan. Stat. Ann. 21-6819(b)(4) when it imposed the 153-month sentence because the sentence was more than double the amount of prison time Defendant received for his primary crime of attempted aggravated robbery. View "State v. McClelland" on Justia Law

Law enforcement officers employed by the City of Prairie Village set up a controlled drug buy from Defendant to occur in the City of Leawood. As a result of the controlled buy, the State charged Defendant with felony drug charges. Defendant moved to suppress the drugs and an audio recording of the controlled buy, arguing that the Prairie Village officers had obtained that evidence while exercising their police powers outside of their jurisdiction as authorized under Kan. Stat. Ann. 22-2401(a)(2). The district court granted the motion and suppressed the evidence. The court of appeals reversed, finding that the Prairie Village officers had jurisdiction in Leawood based on a provision in section 22-2401(a)(2)(b) allowing municipal officers to exceed their jurisdictional boundaries when another jurisdiction requests assistance. The Supreme Court affirmed on different grounds, holding (1) the statutory limitations on the jurisdiction of city officers was put in place to protect the local autonomy of neighboring cities and counties, rather than to create an individual right; and (2) consequently, the suppression of any evidence obtained during a city officer’s unauthorized exercise of police power outside the officer’s employing city will generally not be required. View "State v. Vrabel" on Justia Law

In 2009, E.J.D. entered a plea of no contest to battery on juvenile detention officers. The court determined that the proceedings should be designated as an extended-jurisdiction juvenile prosecution and sentenced E.J.D. to a term in a juvenile correction facility and to an adult criminal sentence. The court stayed the adult criminal sentence on the condition that E.J.D. not violate the provisions of the juvenile sentence and on the condition that he not commit a new offense. The State subsequently moved to revoke the stay of execution of the adult sentence based on numerous disciplinary violations committed by E.J.D. Thereafter, E.J.D. moved for a lesser sentence and a durational departure from his sentence. The district court denied E.J.D.’s motion and ordered him committed to the custody of the Department of Corrections. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the statutory scheme does not allow modification of an adult sentence after a determination that a juvenile has violated the terms and conditions of an extended jurisdiction juvenile prosecution; and (2) the court of appeals correctly determined that the evidence supported the district court’s decision to revoke the stay of execution of the adult sentence. View "In re E.J.D." on Justia Law

A seven-year-old child was killed in a one-car rollover crash. The child’s parents had periodically traded driving duties during the trip, and Mother was driving when the accident occurred. Father brought a wrongful death action against Mother, alleging that Mother’s negligence was the proximate cause of the child’s death. The jury found both parties fifty percent at fault, which resulted in a judgment in favor of Mother. The court of appeals affirmed. The Supreme Court reversed, holding (1) this action was not barred because Mother was both a potential tortfeasor and heir at law; (2) the district court did not err in denying Mother’s motion for summary judgment and her motion for judgment as a matter of law; and (3) the district court erred in instructing the jury on comparative fault, and the error was not harmless. View "Siruta v. Siruta" on Justia Law

In 2008, the City of Basehor initiated a unilateral annexation of Cedar Lake Estates (Estates), a platted subdivision adjoining the City. Trustees of the Stueckemann Living Trust and the Cedar Lake Association (collectively, the Stueckemanns), sued the City seeking to invalidate the annexation on multiple grounds. The district court rejected all of the Stueckemanns’ contentions and upheld the City’s annexation. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court and court of appeals did not err by concluding that (1) the City’s plan adequately described the land subject to the annexation; (2) the City’s service plan for police protection and for street and infrastructure maintenance was adequate; and (3) the City’s annexation was reasonable. View "Stueckemann v. City of Basehor" on Justia Law

After a jury trial, Defendant was convicted of six drug offenses. The court of appeals affirmed in part and reversed in part, resulting in a reversal of one of Defendant’s convictions and the vacating of one of his sentences. Those issues were not before the Supreme Court for review. On appeal, Defendant sought the Court’s review of that portion of the court of appeals’ decision that was adverse to him. The Supreme Court affirmed, holding that the district court did not err in (1) denying Defendant’s motion to suppress evidence obtained from the warrantless search of his vehicle; (2) convicting Defendant for the separate offenses of possessing red phosphorous and iodine and possessing drug paraphernalia with intent to manufacture, as those convictions were not multiplicitous; and (3) using Defendant’s prior convictions to enhance his sentence. View "State v. Overman" on Justia Law

In 1969, Grantors and an oil company entered into a continuing oil and gas lease covering Grantors’ property. Less than seven months later, Grantors entered into a mineral deed with Grantee covering the same property. The mineral deed had a primary term of fifteen years. In 2012, Plaintiffs, the sole heirs of Grantors, filed a declaratory judgment seeking a declaration that the royalty interest held by Defendants, the sole heirs of Grantee, had terminated. The district court granted summary judgment for Defendants, concluding that because the mineral deed stated that it was subject to the terms of the continuing oil and gas lease and because Grantor was a party to both the lease and the mineral deed, the parties intended that they be read together. The Supreme Court reversed, holding (1) the “subject to” clause in the mineral deed did not incorporate the provisions of the lease; and (2) therefore, Defendants’ mineral interest did not continue past its fifteen-year term. View "Netahla v. Netahla" on Justia Law

After a jury trial, Defendant was convicted of premeditated first-degree murder. The Supreme Court affirmed, holding (1) Defendant was not entitled to an instruction on self-defense; (2) the district court did not commit clear error by failing to instruct on second-degree intentional murder; (3) the prosecutor committed misconduct during closing arguments by vouching for the credibility of some witnesses, discussing facts not in evidence, and disparaging the defense, but the statements did not deprive Defendant of a fair trial; (4) the district court did not err in excluding evidence suggesting that a third party might have had a motive to commit the murder; (5) Defendant did not preserve his argument that the district court violated his confrontation rights by limiting cross-examination of a state witness; and (6) the presumed instructional error and the instances of prosecutorial misconduct did not cumulatively deny Defendant a fair trial. View "State v. Knox" on Justia Law