Justia Kansas Supreme Court Opinion Summaries

Plaintiff, an inmate in the custody of the Kansas Department of Corrections (DOC), took advantage of a statutorily created inmate trust fund to place money in the custody of the DOC for his use while serving his sentence. Plaintiff filed suit in Leavenworth District Court pursuant to the Kansas Uniform Trust Code (KUTC) alleging that Defendants were in breach of trust by charging various fees against the balance held in his inmate fund. Defendants successfully moved to transfer venue to Norton District Court. Plaintiff filed a motion to transfer venue back to Leavenworth District court, claiming that because the inmate trust fund was administered at the Lansing Correctional Facility in Leavenworth County, his claims under the KUTC could only be brought in Leavenworth District Court pursuant to Kan. Stat. Ann. 58a-204. The Norton District Court denied Plaintiff’s motion and granted summary judgment to Defendants on all of Plaintiff’s claims. The Court of Appeals affirmed, concluding that Plaintiff could have filed his suit in Norton County under Kan. Stat. Ann. 60-602(2). The Supreme Court reversed, holding (1) the inmate trust is a trust subject to the KUTC; and (2) the KUTC establishes exclusive venue in the county were the inmate trust fund is administered - i.e., in Leavenworth County. View "Matson v. Kan. Dep’t of Corr." on Justia Law

While fleeing the police during a high-speed chase, Defendant collided with another vehicle, killing both occupants. After a jury trial, Defendant was convicted of two counts of first-degree felony murder and one count of fleeing or attempting to elude a police officer. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by urging defense counsel to complete voir dire or setting a time limitation on the second day; (2) the district court’s remark in the jury’s presence about the time defense counsel was taking during voir dire was not improper or prejudicial; (3) the district court did not err in refusing to change venue; (4) the prosecutor made a misstatement as to the process for considering lesser included offenses, but the misstatement did not so prejudice the jury as to deny Defendant a fair trial; and (5) the State properly charged felony murder rather than involuntary manslaughter while driving under the influence. View "State v. Hudgins" on Justia Law

The decedent in this case died from an acute intra-abdominal bleed from a hematoma with adjacent tissue damage. The day before his death, the decedent visited an emergency department, where CT scans of the decedent’s abdomen, pelvis, and chest were performed and sent to Defendant, a radiologist. The decedent’s widow (Plaintiff) sued the radiologist, alleging that the radiologist negligently evaluated the CT scans. The district court granted summary judgment for Defendant, concluding that Plaintiff failed to establish that Defendant’s negligence caused the decedent’s death. The Supreme Court affirmed, holding that the district court correctly granted judgment for Defendant because Plaintiff failed to establish causation, an essential element of Plaintiff’s medical malpractice claim, by failing to establish that the decedent would not have died but for Defendant’s alleged breach of the standard of care. View "Drouhard-Nordhus v. Rosenquist" on Justia Law

Defendant pled guilty to one count of first-degree murder. Just over one year later, the clerk of the district court received a pro se motion for postconviction relief pursuant to Kan. Stat. Ann. 60-1507, in which Defendant alleged that he received ineffective assistance of counsel. Defendant filed his supporting memorandum less than one month later. The district court summarily denied the motion, concluding that Defendant had waived his right to file a section 60-1507 motion based on the purported ineffective assistance of counsel and that the motion was time-barred. The Court of Appeals affirmed but on different grounds, concluding that Defendant’s supporting memorandum should be treated as an attempted section 60-1507 amendment and that the amendment was time-barred. The Supreme Court reversed, holding (1) the district court erred by concluding that Defendant waived his right to file a section 60-1507 motion alleging ineffective assistance of counsel; (2) the district court erred by concluding that Defendant failed to file his section 60-1507 motion within the one-year time limitation in Kan. Stat. Ann. 60-1507(f)(1); and (3) the Court of Appeals erred in affirming the district court’s dismissal after treating the supporting memorandum as an untimely amendment. Remanded. View "Wahl v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder and arson. The district court imposed a hard fifty life sentence after finding that Defendant committed the murder in an especially heinous, atrocious, or cruel manner. The Supreme Court affirmed the convictions but vacated the sentence and remanded for resentencing, holding (1) the district court did not err in denying Defendant’s request for a jury instruction on self-defense; (2) any error in denying Defendant’s request for a voluntary manslaughter instruction based on a theory of imperfect self-defense was harmless; (3) the district court erred in admitting Defendant’s recorded confession when Defendant unambiguously invoked his right to have counsel present during custodial interrogation, but the error was harmless; and (4) Defendant’s hard fifty sentence was unconstitutional under Alleyne v. United States because the district court denied Defendant the right to have a jury decide beyond a reasonable doubt all of the facts that may increase the penalty for first-degree murder. View "State v. Salary" on Justia Law

After a jury trial, Defendant was found guilty of felony murder and criminal discharge of a firearm at an occupied building. During trial, the jury received instructions on second-degree unintentional murder and involuntary manslaughter as lesser included offenses of felony murder. Defendant appealed, arguing that the prosecutor misstated the law - thus, committing misconduct - when he told the jurors during closing arguments that they were to consider Defendant’s guilt for the lesser included crimes only after finding him not guilty of felony murder. The Supreme Court affirmed, holding (1) the prosecutor’s statement was erroneous because it suggested to the jury that it must unanimously acquit him of felony murder before considering his guilt for the lesser included crimes; but (2) because the prosecutor also recited the correct legal standard during closing arguments and the overwhelming evidence established Defendant’s guilt for felony murder, the prosecutor’s erroneous statement did not constitute reversible misconduct. View "State v. Parker" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The district judge imposed a hard forty life sentence. By way of a journal entry five months later, the district judge set amounts for restitution and court costs. The Supreme court affirmed, holding (1) Defendant’s conviction bestowed jurisdiction to sentence upon the district court, and the district judge’s pronounced sentenced conformed to the statutory requirements; (2) Defendant’s sentence was not illegal because it became final when the district court judge memorialized the amount of restitution in a journal entry; and (3) the district judge’s failure to hold a hearing in open court with Defendant present to set the amount of restitution did not deprive the district court of jurisdiction or make the sentence illegal. View "State v. Moncla" on Justia Law

After a jury trial in this Jessica’s Law case, Defendant was convicted of two counts of aggravated indecent liberties with a child. Following his direct appeal, Defendant filed a motion to arrest judgment pursuant to Kan. Stat. Ann. 22-3503, arguing that the charging document in his case was fatally defective and deprived the district court of jurisdiction to convict him because it failed to include the essential element that he was eighteen or older at the time of the alleged crimes. The district court denied the motion. The Court of Appeals dismissed the appeal. The Supreme Court reinstated the appeal but affirmed the judgment of the district court, holding (1) the Court of Appeals should not have dismissed Defendant’s appeal for lack of jurisdiction; but (2) Defendant may not raise a collateral challenge to the charging document in a section 22-3503 motion filed well after his direct appeal. View "State v. Sellers" on Justia Law

After a jury trial, Defendant was convicted of capital murder, vehicle burglary, and theft. The Supreme Court affirmed, holding (1) the trial court did not err when it denied Defendant’s motion for change of venue; (2) even if the trial court erred in failing to instruct on the lesser included offense of felony murder, Defendant was not entitled to the requested relief of a new trial during which the jury would receive a felony-murder instruction; (3) any error in failing to instruct on the lesser included offense of reckless second-degree murder was harmless; (4) the trial court did not err in admitting a before-death photograph of the victim; (5) the trial court did not rule unreasonably in admitting a video of Defendant’s arrest; (6) the prosecutor did not commit misconduct during closing arguments; (7) the trial court did not err in failing to declare a mistrial; and (8) sufficient evidence supported the conviction for capital murder. View "State v. Longoria" on Justia Law

Defendant was visiting the home of a long-time acquaintance when police officers arrived. One of the officers walked to the backyard of the property and found a baggie of methamphetamine on the ground. Defendant was arrested and transported to jail, where officials discovered a baggie of marijuana during an inventory search of Defendant's belongings. Defendant was charged with several drug-related crimes. The district court granted Defendant’s motion to suppress, concluding that the methamphetamine was found in the curtilage of the home, that a social guest such as Defendant has standing to assert a host’s Fourth Amendment rights in the curtilage, and that marijuana found on Defendant was fruit of the poisonous tree. The Court of Appeals reversed. The Supreme Court reversed the Court of Appeals and affirmed the district court, holding (1) the Court of Appeals erred in reversing because the district court’s findings that the backyard was curtilage were supported by substantial competent evidence, and case law supported its legal conclusion that the area was curtilage; (2) a social guest has standing to challenge a search of the curtilage of the host’s residence; and (3) the marijuana should be suppressed as fruit of the poisonous tree. View "State v. Talkington" on Justia Law