Justia Kansas Supreme Court Opinion Summaries

In two cases consolidated for trial, a jury convicted Patrick Naputi on seven counts of aggravated indecent liberties with a child under the age of fourteen. The district court granted Naputi's departure motion and imposed a sentence that included 122 months of incarceration, lifetime electronic monitoring, and lifetime postrelease supervision. The Supreme Court affirmed the convictions but vacated the portion of the sentence ordering lifetime electronic monitoring in accordance with State v. Jolly, which states that the parole board has the sole authority to impose the electronic monitoring condition of parole. Remanded with instructions to eliminate the electronic monitoring requirement. View "State v. Naputi" on Justia Law

After a jury trial, Xavier Miller was convicted of intentional second-degree murder. The court of appeals affirmed Miller's conviction. At issue on review was whether the district court clearly erred when it appropriately instructed the jury that it should simultaneously consider the lesser-included offenses of second-degree murder and voluntary manslaughter, but then erroneously gave a contradictory instruction directing the jury to consider the offense of voluntary manslaughter only if it could not agree on the offense of second-degree murder. The Supreme Court reversed Miller's conviction and remanded for a new trial, holding that there was a real possibility the jury would have rendered a different verdict had it not received the inappropriate and contradictory instruction to consider the lesser-included offenses sequentially rather than simultaneously. View "State v. Miller" on Justia Law

While FBI task-force officers were looking to execute an arrest warrant for Shane Thompson, the officers saw Defendant Robert Johnson walking on a sidewalk. After requesting identification, the officers searched Johnson and discovered marijuana and crack cocaine. Johnson was charged with possession of cocaine and possession of marijuana. Johnson filed a motion to suppress, arguing there was a lack of reasonable suspicion to detain him. The district court denied the motion after listening to testimony describing the similarities between Defendant and Thompson. Johnson was convicted of the charges. The court of appeals affirmed. The Supreme Court reversed and vacated Defendant's sentences, holding that Johnson was illegally seized because (1) the State failed to meet its burden to show that it was reasonable for the officers to rely on a face sheet in detaining Defendant; and (2) detaining Defendant because he shared the generic common features with Thompson of being a black male with facial hair was not, without more, sufficient to give officers reasonable suspicion of criminal activity. View "State v. Johnson" on Justia Law

Property owners appealed a special tax assessment the Board of County Commissioners levied against real property for cleanup costs the County claimed it incurred while removing dangerous structures and unsightly conditions on that property. The district court found subject matter jurisdiction lacking and granted the County's summary judgment motion. The court of appeals affirmed. At issue on appeal was whether the property owners' claims could be brought on direct review under Kan. Stat. Ann. 60-907(a), which provides injunctive relief against an illegal levy or enforcement of any tax, charge, or assessment. The Supreme Court affirmed and in part and reversed in part, holding (1) the property owners satisfied the jurisdictional burdens under section 60-907(a) on two of its three issues; and (2) because the district court went beyond the jurisdiction question and found for the County on the merits and the court of appeals stopped short of considering the merits of any claims when it found the entire case was jurisdictionally barred, the court of appeals erred in part in its jurisdictional ruling. Remanded to the court of appeals to determine whether the district court properly granted summary judgment as to the remaining claims. View "Barnes v. Board of County Comm'rs" on Justia Law

Progressive Products, Inc. (PPI) filed a four-count complaint in district court against Defendants, former employees of PPI, on various theories alleging Defendants misappropriated protected trade secrets. The trade secrets at issue were a formula, computerized customer lists, and a computerized pricing program. The district court entered judgment for PPI, holding that Defendants misappropriated protected trade secrets possessed by PPI. The court then imposed a royalty injunction on Defendants. The court of appeals affirmed in part and reversed in part, holding (1) PPI owned protected trade secrets relating to the formula, (2) the price lists were not trade secrets as a matter of law, (3) no evidence supported a finding the customer lists were a trade secret, and (4) the royalty injunction was not supported by the district court's factual findings and did not comport with the available statutory remedies. The Supreme Court affirmed the court of appeals' judgment regarding the protected trade secrets but reversed the court of appeals' opinion reversing the remedy the district court ordered, holding that because the district court's findings were incomplete, they did not permit meaningful appellate review. Remanded. View "Progressive Products, Inc. v. Swartz" on Justia Law

Joseph Pace pleaded guilty to aggravated criminal sodomy. Pursuant to the plea agreement, all other counts were dismissed. Pace filed a motion for a downward durational sentencing departure. The district court denied Pace's motion and imposed a life sentence with a mandatory minimum term of imprisonment of twenty-five years. The court also ordered lifetime electronic monitoring when Pace was paroled. The Supreme Court (1) affirmed Pace's life sentence with a mandatory minimum term of imprisonment of twenty-five years, (2) affirmed the district court's denial of Pace's downward departure motion, and (3) vacated the parole condition of lifetime electronic monitoring because the imposition of parole conditions, including lifetime electronic monitoring, is the province of the parole board and lies outside the jurisdiction of the sentencing court. View "State v. Pace" on Justia Law

Luiz Mendoza pleaded no contest to rape with a victim who was eleven years old. As part of the plea agreement, the State dismissed all other charges and agreed to recommend a downward departure to the sentencing grid. Mendoza filed a motion for a downward sentencing departure based on his lack of criminal history. The district court denied the departure motion and sentenced Mendoza to life in prison without parole for twenty-five years. The court also imposed lifetime postrelease supervision and lifetime electronic monitoring because Mendoza was convicted of a child sex offense. The Supreme Court (1) affirmed Mendoza's life sentence without parole eligibility, (2) vacated the parole condition of lifetime electronic monitoring because the imposition of parole conditions is the province of the parole board and lies outside the jurisdiction of the district court, and (3) affirmed the district court's denial of the downward departure motion. View "State v. Mendoza" on Justia Law

Shane Marquis was placed on probation after being convicted of drug charges and felony theft. Later, the State sought to revoke Marquis' probation, claiming he failed to successfully complete a required boot camp. At the revocation hearing, the community corrections officer assigned to Marquis' case did not testify, but, instead, the State presented the officer's affidavit. The district court determined that Marquis violated the conditions of his probation and revoked the probation. Marquis appealed, contending that the district court violated his right of confrontation by considering his supervising officer's affidavit without complying with the requirements for the admission of testimonial hearsay set forth in Crawford v. Washington. The Supreme Court reversed, holding that although the Sixth Amendment right to confrontation is inapplicable in a probation revocation proceeding, the Fourteenth Amendment affords a probation minimum due process rights as a prerequisite to the revocation of probation. Remanded for the district court to inquire as to whether the State's failure to produce the supervising officer as a witness violated Marquis' due process rights. View "State v. Marquis" on Justia Law

Will Wimbley was convicted of premeditated first-degree murder and criminal possession of a firearm. His convictions were affirmed on appeal. Wimbley filed two motions for postconviction relief. At issue in the motions were (1) the prosecutor's closing statement that "premeditation can occur in an instant," and (2) questions surrounding DNA evidence on the murder weapon. Wimbley's first motion was denied by the district court. The court of appeals affirmed. In his second motion for postconviction relief, Wimbley argued that a recent Supreme Court decision, State v. Holmes, represented an intervening change in the law. The district court summarily denied the motion, finding the motion was successive and untimely. The court of appeals held that Holmes represented a clear change in the law, and therefore, reversed Wimbley's underlying convictions and remanded for a new trial. On review, the Supreme Court found the district court's rulings to be appropriate and reversed the court of appeals, holding (1) Holmes did not change the legal definition of premeditation but rather looked at the prejudicial impact of a prosecutor's misstatement that premeditation can occur in an instant, and (2) the district court was justified in declining Wimbley's request for retesting of the murder weapon. View "Wimbley v. State" on Justia Law

At issue here was a reserved question in Koplin v. Rosel Well Perforators of whether Kansas would recognize the tort of intentional interference with a prospective civil action by spoliation of evidence if a defendant or potential defendant in an underlying case destroyed evidence to their own advantage. Plaintiff Superior Boiler Works brought suit against Defendants, a company and two individuals, for intentional and negligent interference with actual and prospective actions by destruction of evidence. Defendants had destroyed company records after Superior sought information for use in asbestos-related litigation regarding asbestos content in materials Superior supplied to Defendants. The district court granted summary judgment to Defendants, finding (1) Defendants had no duty to preserve the records, and (2) the reserved question in Koplin did not apply to spoliation claims between those who are potential codefendants in the underlying action. The Supreme Court affirmed, holding (1) simply being in the chain of distribution of a product or in the stream of commerce, without more, is not a special relationship that gives rise to a duty to preserve evidence, and (2) an independent tort of spoliation will not be recognized in Kansas for claims by a defendant against codefendants or potential codefendants. View "Superior Boiler Works, Inc. v. Kimball" on Justia Law