Justia Kansas Supreme Court Opinion Summaries

The Supreme Court answered two certified questions regarding the interplay between an arbitrated award against one set of tortfeasors and a litigated proceeding against another set of tortfeasors in this case concerning Kansas's one-action rule.Timothy Hunt, a farm employee, was killed when operating a grain vacuum to remove corn from a grain trailer. Plaintiff, Hunt's daughter, filed suit in Kansas federal district court against the manufacturer of the grain vacuum system. In the meantime, Hunt's children, including Plaintiff, entered into an arbitration agreement with the farm. An arbitrator entered an award in favor of the claimants. The circuit court entered final judgment confirming the arbitration award. The defendants in the federal court action subsequently moved for summary judgment, arguing that the suit was barred by the one-action rule. The federal court then certified questions to the Supreme Court. The Supreme Court answered (1) an arbitration action does not qualify as a judicial determination of comparative fault where no other potential tortfeasors were involved in the arbitration; and (2) the confirmation of an arbitration award by a state court judgment does not qualify as a judicial determination of comparative fault so as to invite application of the Kansas one-action rule. View "Hodges v. Walinga USA Inc." on Justia Law

The Supreme Court affirmed the order of the district court reversing its order suppressing evidence found in the car that Defendant was driving on two separate occasions where law enforcement discovered drugs and other contraband, holding that the district court did not abuse its discretion in reversing its suppression order but erred in admitting prior drug use.Defendant was convicted by a jury of two counts of possessing methamphetamine and four counts of possessing drug paraphernalia with intent to use to distribute. The court of appeals reversed and remanded for a new trial on the ground that the district court erroneously allowed the State to introduce evidence relating to Defendant's prior convictions for similar crimes. The Supreme Court affirmed, holding (1) the district court erred in admitting prior drug crime evidence, and the error was not harmless; and (2) the district court did not abuse its discretion in granting the State's motion to reconsider its erroneous suppression ruling. View "State v. Campbell" on Justia Law

The Supreme Court reversed the decision of a panel of the court of appeals reversing the district court's determination that a prescriptive easement existed over land owned by the Galls, holding that the panel erred in finding that the Pyles' use was not exclusive because the Pyles did not exclude all others from the asserted easement.The Pyles filed petition seeking to quiet title to a disputed boundary land in this case. The district court found that the Pyles acquired the land by adverse possession and acquired a prescriptive easement across the northern sixty feet of the Galls' land. The court of appeals affirmed the court's adverse possession findings but reversed the finding of a prescriptive easement, concluding that the evidence did not show that the Pyles exclusively used the northern boundary of the Galls' land. The Supreme Court reversed as to the issue subject to review, holding that the element of exclusivity was established in this case in the context of a prescriptive easement. View "Pyle v. Gall" on Justia Law

The Supreme Court affirmed the judgment of the district court granting an uncontested petition of the trustees of the Marvin S. Robinson Charitable Trust to retroactively modify the trust's terms to maintain its tax-exempt status as a "supporting organization" under the federal tax code, holding that Kan. Stat. Ann. 58a-416 authorized the retroactive modification of the trust.Under In Commissioner v. Estate of Bosch, 387 U.S. 456 (1967), which held that the Internal Revenue Service (IRS) and federal courts are not bound by decisions of lower state courts on issues of state law but that these entities will defer to decisions of a state's highest court, an order allowing the retroactive modification of a trust's terms to maintain its tax-exempt status is binding on federal tax authorities only if it emanates from the Supreme Court. The Supreme Court agreed to review the district court's order in accordance with Bosch and affirmed the district court's judgment granting the petition, holding modification of the trust was proper. View "In re Marvin S. Robinson Charitable Trust" on Justia Law

The Supreme Court affirmed the judgment the district court ruling against Defendant on his "Motion to Void Restitution, Reimbursements for Indigent Defense Services and Court Cost and Fees and Witness Fees" based on the law-of-the-case doctrine, holding that there was no error.Defendant, who was serving a life sentence for felony murder, challenged the district court's order of restitution in the amount of $37,521. The court concluded that the State had wrongly been collecting restitution from Defendant's prison account based on a clerical error and ordered it corrected. Defendant further requested that he be refunded $3,347 already improperly collected from his account. The court denied the motion, and the court of appeals affirmed. While his appeal was pending, Defendant filed the motion at issue, repeating an earlier argument that the restitution order was dormant and therefore void. The district court denied the motion, citing the law-of-the-case doctrine. The Supreme Court affirmed, holding that the district court did not err in ruling against Defendant based on the law-of-the-case doctrine. View "State v. Bailey" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals panel reversing the ruling of the district court denying Lisa Webster's request to clarify an order made during her divorce proceedings that she receive a share of Jon's Army Reserve and National Guard retirement pay based on the months of their marriage, holding that the relief from judgment statute, Kan. Stat. Ann. 60-260, was not applicable.When Jon retired about fifteen laters following the parties' divorce Lisa submitted the court's division order to the federal office administering Jon's retirement benefits, but the office told Lisa that it needed more detail to calculate Lisa's share. Lisa filed a motion seeking clarification of the order, which the district court denied. The court of appeals reversed, concluding that the division order was not a final judgment subject to the dormancy statute. The Supreme Court affirmed on different grounds, holding (1) the division order was a final judgment subject to the dormancy statute; and (2) section 60-260 was not applicable because Lisa's request for clarification did not require substantive change to the original property division. View "In re Marriage of Shafer" on Justia Law

In this action involving a district court's division of Jon Holliday's retirement account in a divorce proceeding with Tamara Holliday the Supreme Court held that Kan. Stat. Ann. 60-2403(c)'s tolling provision prevents a divorce decree dividing the parties' interests in a retirement account with the Kansas Public Employees Retirement System (KPERS) from becoming dormant until benefits become payable to the plan member.In 2009, Jon and Tamara divorced. The district court divided Jon's not-year-payable retirement account with KPERS equally between them and directed Tamara to prepare a qualified domestic relations order to "effectuate" the division. In 2021, Jon brought this action claiming that Tamara's judgment from the divorce had gone dormant because she had not sent a copy of it to KPERS as instructed and requesting that the court extinguish Tamara's interest in the account. The district court denied relief, but the court of appeals reversed. The Supreme Court reversed, holding that Kan. Stat. Ann. 60-2403(c) tolled the dormancy period until Jon's benefits from his KPERS account became payable. View "In re Marriage of Holliday" on Justia Law

The Supreme Court reversed the judgment of a panel of the court of appeals reaching the merits of Defendant's appeal of his conviction and sentence, holding that this Court expressly overrules its prior opinion in State v. Duncan, 243 P.3d 338 (Kan. 2010), and to the extent that the panel relied on Duncan to reach the merits of the appeal the court of appeals erred.Pursuant to a plea agreement, Defendant pled guilty to two counts of sexual exploitation of a child. The court of appeals affirmed, thus rejecting Defendant's argument that his sentence was illegal because he was not advised of and did not knowingly and voluntarily waive his right to a jury trial on the upward departure aggravating factors. The Supreme Court reversed and dismissed the appeal, holding (1) a claim challenging the constitutional validity of a waiver relinquishing the statutory right under Kan. Stat. Ann. 21-6817(b) to have a jury determine the existence of upward departure aggravating factors falls outside the definition of an illegal sentence; and (2) absent a valid illegal sentence claim under section 22-3504, an appellate court has no jurisdiction to review a sentence resulting from an agreement between the State and the defendant that the court approves on the record. View "State v. Johnson" on Justia Law

The Supreme Court affirmed Defendant's convictions for several crimes after he intentionally set a fire that damaged several apartments, holding, among other things, that the Kansas Legislature has defined the unit of prosecution for aggravated arson as each damaged building or property in which there is a person.Defendant intentionally set fire in the stairwell in front of his daughter's apartment, leading to his conviction, following a jury trial, of six counts of aggravated arson, three counts of attempted first-degree murder, and one count of animal cruelty. On appeal, Defendant argued, among other things, that the district court judge violated his right to be free from double jeopardy by sentencing him on six counts of aggravated arson when the arsonist started only one fire. The Supreme Court disagreed and affirmed, holding (1) Defendant's right to be free from double jeopardy was not violated; (2) the State presented sufficient evidence to support Defendant's convictions for attempted first-degree murder; and (3) the trial judge did not err in denying Defendant's untimely motion for a new trial. View "State v. Buchanan" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court's ruling in this eminent domain case between Tenants and City involving the requirement that a condemning authority provide certain relocation benefits and assistance to those displaced by the government's exercise of eminent domain, holding that the district court lacked subject matter jurisdiction over Tenants' petition to recover relocation expenses.Specifically, the Supreme Court held (1) the district court lacked subject matter jurisdiction over Tenants' petition because the Kansas Eminent Domain Procedure Act (EDPA), Kan. Stat. Ann. 26-501 et seq., neither provides a private right of action to recover relocation benefits nor authorizes judicial review of relocation-benefit determinations in eminent-domain appeals; (2) while the Kansas Relocation Assistance for Persons Displayed by Acquisition of Real Property Act (KRA), Kan. Stat. Ann. 58-3501 et seq., does provide an administrative remedy to vindicate the statutory right to relocation benefits, Tenants' failure to exhaust this administrative remedy deprived the district court of subject matter jurisdiction under the KRA; and (3) while Kan. Stat. Ann. 60-2101(d) authorizes appeals to the district court from certain final judgments and orders of a political subdivision, the statute did not apply in this case. View "Kan. Fire & Safety Equipment v. City of Topeka" on Justia Law