Justia Kansas Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals reversing the decision of the trial court judge dismissing this case with prejudice after suppressing evidence as a discovery sanction, holding that, under the circumstances, the district court did not abuse its discretion in dismissing the case with prejudice.Defendant was charged with drug-related offenses. The district court ultimately dismissed the charges with prejudice after suppressing certain evidence as a discovery sanction. The court of appeals reversed and remanded hte case, concluding that the district court abused its discretion by dismissing the case with prejudice for a discovery failure. The Supreme Court reversed, holding (1) the judge infringed on the prosecutor's discretion by not leaving to the prosecutor the decision of whether to proceed to trial; and (2) the error was harmless. View "State v. Mulleneaux" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing this lawsuit after its prior decision that a 2006 agreement between the cities of Spring Hill and Olathe was unenforceable as a governmental action that could not bind subsequent city councils, holding that Olathe was not entitled to relief on any of its claims of error.The agreement at issue restricted the cities' future growth by establishing boundaries for annexing land lying adjacent to the two cities. The agreement had no fixed expiration term and stated that termination could occur only upon mutual consent of the parties. In 2021, Olathe filed a petition seeking preliminary and injunctive relief to restrain Spring Hill from annexing certain disputed property. The district court denied the request for injunctive relief and then dismissed the suit. The Supreme Court affirmed, holding that the agreement was an unenforceable attempt to bind future city councils to a governmental policy decision. View "City of Olathe v. City of Spring Hill" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of a panel of the court of appeals affirming Defendant's conviction of possession of more than 3.5 grams of methamphetamine with intent to distribute, possession of a firearm within ten years of a prior felony conviction, and two counts of drug paraphernalia possession, holding that insufficient evidence supported Defendant's firearm possession conviction.On appeal, Defendant raised six allegations of error. The Supreme Court reversed in part, holding (1) the panel erred when it refused to consider for the first time on appeal the legal appropriateness of an intent-to-distribute instruction and the instruction's permissive inference was legally inappropriate, but this error was not prejudicial; (2) Defendant's constitutional challenges failed; (3) there was insufficient evidence to support Defendant's firearm conviction; and (4) Defendant was not entitled to relief on his remaining claims of error. View "State v. Valdez" on Justia Law

The Supreme Court reversed the judgment of the Board of Tax Appeals (BOTA) concluding that Johnson County's valuations for the 2016 and 2017 tax years involving eleven Walmart and Sam's Club "big box" stores in the County were too high because they improperly relied on unadjusted sales and rental income data from other properties subject to build-to-suit leases, holding that In re Prieb Properties, LLC 275 P.3d 56 (2012), is overruled.The BOTA in this case did its duty to follow Prieb, a 2012 decision that crafted a rule of law to exclude appraisal opinions founded on unadjusted build-to-suit lease data to support valuations used in the process of ad valorem taxation. The court of appeals affirmed. The Supreme Court remanded the case, holding (1) Prieb's rationale invades BOTA's longstanding province as the fact-finder in the statutory process for appraising real property at its fair market value for ad valorem tax purposes; and (2) by following Prieb, BOTA improperly imposed an exclusionary rule on the County's evidence rather than simply considering its weight and credibility. View "In re Equalization Appeal of Walmart Stores, Inc." on Justia Law

The Supreme Court reversed the judgment of the lower court finding the legislative reapportionment in the map colloquially known as "Ad Astra 2" constitutionally deficient as a partisan and racial gerrymander, holding that Plaintiffs did not prevail on any of their claims that Ad Astra 2 violates the Kansas Constitution.The district court held that Sub. SB 355 violates the Kansas Constitution as both a partisan and a racial gerrymander. The Supreme Court reversed, holding (1) this Court had jurisdiction to hear Plaintiffs' claims; (2) claims of excessive partisan gerrymandering are nonjusticiable in Kansas; and (3) Plaintiffs did not establish the elements of their race-based claims. View "Rivera v. Schwab" on Justia Law

The Supreme Court upheld the validity of Substitute for Senate Bill 563 (Sub. SB 563), holding that the Kansas State House and Kansas State Senate reapportionment maps contained within Sub. SB 563 contain no constitutional errors.The two maps at issue were approved by bipartisan majorities, and Sub. SB 563 was signed into law on April 15, 2022. On April 25, Attorney General Derek Schmidt petitioned the Supreme Court to determine the validity of Sub. SB 563, as required by Kan. Const. art. 10, 1(b). The Supreme Court held that Sub. SB 563 passed constitutional muster because the legislative maps contained therein satisfied the constitutional requirement of one person one vote, they were not discriminatory, and they satisfied the requirements of the Voting Rights Act. View "In re Validity of Substitute for Senate Bill 563" on Justia Law

The Supreme Court affirmed Defendant's conviction for failing to register as a violent offender in Shawnee County in November 2017, holding that there was sufficient evidence to support the conviction.Defendant's obligation to register under the Kansas Offender Registration Act, Kan. Stat. Ann. 22-4902 et seq., arose after he was found guilty of robbery and criminal use of a financial card. After Defendant was released from prison, he failed to register in Shawnee County during November 2017. The State subsequently charged him with a registration violation under section 22-4905(b). A jury convicted Defendant of violating the registration requirements. Defendant appealed, arguing that the jury could not reasonably infer that he resided in Shawnee County in November 2017. The Supreme Court affirmed, holding that the evidence provided a basis for a reasonable inference that Defendant resided in Shawnee County in November 2017. View "State v. Huey" on Justia Law

The Supreme Court affirmed Defendant's convictions for two counts of first-degree premeditated murder, holding that any error in this case did not affect the verdict and was therefore harmless.On appeal, Defendant asserted multiple claims of trial error, including a claim that the district court clearly erred by failing to provide the jury with a cautionary instruction on the reliability of eyewitness identifications. The Supreme Court affirmed the convictions, holding (1) the district court erred by failing to provide the cautionary instruction, which was legally and factually appropriate, at trial, but the court's instructional error did not warrant reversal; and (2) Defendant's remaining claims of error were without merit. View "State v. Shields" on Justia Law

In 2004, Ross was convicted of first-degree murder, attempted first-degree murder, and criminal possession of a firearm. He was sentenced to life imprisonment plus nine months (consecutive) for criminal possession of a firearm. The Kansas Supreme Court affirmed. Ross continued to seek relief through several post-conviction motions.In 2021, Ross filed a pro se motion captioned "Informational defect/Lack of Jurisdiction under K.S.A. 22-3201(b)(c)(e)(f)(g)(e)," arguing that the criminal complaint filed by the state "failed to confer subject matter jurisdiction on the trial court" because it failed to state essential facts constituting each of the charged offenses. The district court reviewed the claim on the merits but denied his request for relief: "Charging documents do not bestow or confer subject matter jurisdiction on state courts to adjudicate criminal cases; the Kansas Constitution does. … A charging document shall state "essential facts" constituting the crime charged, and the document "shall be deemed sufficient" if it is "drawn in the language of the statute." In Ross’s case, the charging document adequately stated the elements of the crimes of conviction. The Kansas Supreme Court affirmed. Ross failed to identify a timely, unexhausted, and proper procedural vehicle for presenting his subject matter jurisdiction challenge. View "State v. Ross" on Justia Law

Bailey was convicted of aggravated criminal sodomy in 1988 for his role in an incident in the Wyandotte County jail. Bailey's third petition for forensic DNA testing of biological material from a rape kit was summarily denied. He did not appeal one of the earlier denials but appealed the second and lost on appeal.The Kansas Supreme Court affirmed. Bailey is barred from relitigating the issues he raised by the application of issue preclusion principles to the prior determinations that he cannot meet the threshold requirements of K.S.A. 2020 Supp. 21-2512(a), which allows certain criminally convicted individuals to petition for postconviction forensic DNA testing. The prior rulings holding the state has no biological material related to Bailey's convictions in its actual or constructive possession is determinative of his ability to obtain postconviction forensic testing. View "State v. Bailey" on Justia Law