Justia Kansas Supreme Court Opinion Summaries
State v. Moriarty
The Attorney General alleged that the Chief Judge of the Tenth Judicial District exceeded his authority and contravened Kansas law by issuing an administrative order permitting marriage licenses to be issued to same sex couples. The Attorney General sought an order directing the Chief Judge and clerk of the district court to immediately cease from issuing marriage applications or licenses to same gender couples and an order vacating the Judge’s administrative order. The Supreme Court declined to grant the relief sought, as the Attorney General's right to relief on the merits was not clear, but granted the Attorney General’s alternative request for a temporary stay of the Chief Judge’s administrative order insofar as the order allows issuance of marriage licenses. The Court then requested additional briefing on the pending issues of whether the Chief Judge possessed authority to issue the administrative order and whether the interpretations and applications of the United States Constitution by the Tenth Circuit Court of Appeals are supreme and modify any Kansas state ban on same-sex marriage. View "State v. Moriarty" on Justia Law
Craig v. FedEx Ground Package Sys., Inc.
Numerous class actions throughout the country were filed against FedEx Ground Package System, Inc. by former and current delivery drivers for the company. Plaintiffs claimed they were improperly classified as independent contractors rather than as employees under both state and federal law. The class actions were consolidated, and the Kansas class action was designated as the lead case. A federal district court granted summary judgment for FedEx, determining that the Kansas class plaintiffs were independent contractors under the Kansas Wage Payment Act (KWPA). The district court relied on this decision to enter summary judgment for FedEx in all the other statewide class actions, concluding that Plaintiffs were independent contractors, rather than employees, under each respective state’s substantive law. Plaintiffs appealed. The Court of Appeals for the Seventh Circuit certified to the Kansas Supreme Court questions regarding the proper classification of the FedEx drivers under the KWPA. The Supreme Court answered that, under the undisputed facts presented, the plaintiff delivery drivers were employees of FedEx for purposes of the KWPA. View "Craig v. FedEx Ground Package Sys., Inc." on Justia Law
Posted in:
Class Action, Labor & Employment Law
State v. Ortega
After a jury trial, Defendant was convicted of attempted aggravated interference with parental custody and disorderly conduct. The court of appeals found several trial errors, including two instances of prosecutorial misconduct and three jury instruction errors, but concluded that the errors did not deprive Defendant of a fair trial. The Supreme Court reversed Defendant’s conviction for attempted aggravated interference with parental custody and affirmed her conviction for disorderly conduct, holding (1) two of the trial errors, both of which related to Defendant’s defense of ignorance or mistake, warranted the reversal of Defendant’s conviction for attempted aggravated interference with parental custody; and (2) the prejudice Defendant suffered as a result of these errors did not taint her conviction for disorderly conduct, nor did any other claimed errors. View "State v. Ortega" on Justia Law
State v. Hilt
After a jury trial, Defendant was convicted of first-degree premeditated murder, aggravated kidnapping, and aggravated robbery. After the sentencing judge found by a preponderance of the evidence the existence of four aggravating factors, Defendant received a hard fifty life sentence for the first-degree murder conviction. Defendant appealed, raising nine issues challenging his convictions and two challenging his sentences. The Supreme Court (1) affirmed Defendant’s convictions, thus rejecting Defendant’s claims of reversible error; and (2) vacated Defendant’s sentence for first-degree murder, holding that Defendant’s Sixth Amendment right to a jury trial, as interpreted in Alleyne v. United States, was violated because the judge, rather than the jury, found the four aggravating factors existed and did so on a preponderance-of-the-evidence standard, rather than a beyond-a-reasonable-doubt standard.View "State v. Hilt" on Justia Law
State v. Betancourt
After a jury trial, Appellant was found guilty of first-degree murder and criminal discharge of a firearm at an occupied building. The sentencing court sentenced Appellant to a hard twenty-five life sentence for the murder conviction. The Supreme Court affirmed on appeal, holding (1) the district court did not err in instructing the jury; (2) sufficient evidence supported the murder conviction; (3) the district court did not abuse its discretion in denying Appellant’s motion for a mistrial based on a juror’s statement mentioning gang involvement; and (4) because no errors were committed in this case, the cumulative error doctrine did not apply.View "State v. Betancourt" on Justia Law
Posted in:
Criminal Law
State v. Sharkey
After a jury trial, Defendant was convicted of aggravated indecent liberties with a child. The Supreme Court reversed in part, holding that the trial court denied Defendant his right under the Sixth Amendment to have the effective assistance of counsel at a critical stage of the criminal proceedings against him when the court denied Defendant’s pro se motions for a new trial without first appointing new conflict-free counsel to assist Defendant in arguing the motions. Remanded for appointment of new counsel and instructions to hold a new holding on Defendant’s pro se motions for new trial.View "State v. Sharkey" on Justia Law
State v. Alderson
In 1996, Appellant was convicted of one count of felony murder and one count of aggravated battery. As part of Appellant’s sentence, the sentencing court ordered Appellant to pay restitution in the amount of $119,900. No restitution was ever collected from Appellant. In 2009, a private corporation sent Appellant a notice that he had outstanding court fines and that he had to pay $150,904 immediately. Appellant filed a pro se motion requesting release from the restitution order based on dormancy. The district court denied the motion on the grounds that Appellant’s restitution was not yet due, reasoning that restitution cannot be enforced against a defendant while the defendant is incarcerated. The Supreme Court affirmed but on different grounds, holding (1) the district court did not enter an enforceable restitution judgment when it sentenced Appellant; and (2) because there was no pending judgment ordering Appellant to pay restitution, the district court had no jurisdiction to release an obligation on his part.View "State v. Alderson" on Justia Law
Posted in:
Criminal Law
State v. Fritz
Appellant entered a plea of no contest to felony murder, attempted first-degree murder, aggravated robbery, and attempted aggravated robbery. Appellant docketed his appeal from his sentence and then filed a pro se motion to withdraw his plea. Thereafter, Appellant withdrew his motion because his case was pending on appeal. The Supreme Court subsequently vacated the sentence, and the district court resentenced Appellant. That same day, Appellant filed a renewed motion in district court seeking leave to withdraw the no contest plea. The district court denied the motion without an evidentiary hearing. The Supreme Court affirmed, holding (1) a defendant may move to withdraw a guilty plea after a cases is remanded from the appellate courts for resentencing; and (2) the district court did not abuse its discretion in finding that Appellant’s motion failed under either the good-cause or the manifest-injustice standard. View "State v. Fritz" on Justia Law
Posted in:
Criminal Law
State v. Soto
After a jury trial, Defendant was convicted of first-degree murder and sentenced to life imprisonment without the possibility of parole for fifty years. The Supreme Court affirmed Defendant’s conviction but vacated his sentence, holding that Kansas’ hard fifty sentencing scheme violates the Sixth Amendment to the federal Constitution as interpreted in Alleyne v. United States and Ring v. Arizona because it permits a judge to find by a preponderance of the evidence the existence of one or more aggravating factors necessary to impose an increased mandatory minimum sentence, rather than requiring a jury to find the existence of the aggravating circumstances beyond a reasonable doubt. Remanded for resentencing.View "State v. Soto" on Justia Law
State v. Stevenson
The State charged Defendant with possession of methamphetamine after law enforcement officers stopped Defendant’s vehicle based on a turn signal violation, searched the vehicle because they detected a very strong odor of alcohol coming from within the vehicle, and discovered methamphetamine during the search. Defendant filed a motion to suppress the fruits of the warrantless search. The district court denied the motion, concluding that the strong odor of alcohol emanating from within the vehicle established probable cause for the officers to search the vehicle for an open container of alcohol. The Supreme Court reversed, holding that the search was unlawful because the officers failed to acquire additional inculpatory facts relating to the crime being investigated before commencing their search of the vehicle.View "State v. Stevenson" on Justia Law