Justia Kansas Supreme Court Opinion Summaries

A law enforcement officer in Jackson County, Kansas, observed a vehicle with a license plate that was slanting to the right and visibly moving, described as "flapping in the wind." The officer initiated a traffic stop based on the belief that the license plate was not securely fastened as required by Kansas law. During the stop, the officer discovered drugs, drug paraphernalia, and an open container of alcohol in the purse of a passenger, who initially provided a false name. The passenger was subsequently charged with several offenses, including possession of methamphetamine and transportation of liquor in an open container.The passenger moved to suppress the evidence, arguing that the officer lacked reasonable suspicion to stop the vehicle because the license plate was otherwise legible and visible. The Jackson District Court denied the motion, relying on the officer’s testimony and persuasive federal authority interpreting the relevant Kansas statute. The case proceeded to trial, where a jury convicted the passenger on all counts. The Kansas Court of Appeals affirmed the district court’s denial of the suppression motion.The Supreme Court of the State of Kansas reviewed the case. It held that under K.S.A. 8-133(c), a license plate must be securely fastened to the vehicle, in addition to being visible and legible. The court found that the officer’s observation of the plate hanging askew and moving provided reasonable suspicion of a statutory violation, justifying the traffic stop. The court affirmed the decisions of both the Court of Appeals and the district court, holding that the stop was lawful and the evidence was properly admitted. View "State v. Yeargin-Charles " on Justia Law

A sheriff’s deputy in Geary County, Kansas, stopped a vehicle driven by Brian Beck after observing that a license plate frame partially obscured the state name on the plate. Beck was not committing any driving infractions. During the stop, Beck appeared nervous and gave an unusual explanation for his travel route. A canine unit was called, and after the dog alerted, Beck consented to a search of his car, which led to the discovery of over two pounds of methamphetamine. Beck was charged with possession with intent to distribute, possession without a drug tax stamp, and interference with law enforcement. He moved to suppress the evidence, arguing the stop was not supported by reasonable suspicion, but the Geary District Court denied the motion. At trial, Beck renewed his objection, which was again overruled, and a jury convicted him on all counts.On appeal, the Kansas Court of Appeals affirmed the convictions, holding that the partial obstruction of the state name justified the stop under Kansas law, specifically K.S.A. 8-133, which requires license plates to be “clearly visible” and “clearly legible.” The appellate panel reasoned that covering half of the state name violated the statute, regardless of whether the plate could otherwise be identified.The Supreme Court of the State of Kansas reviewed only the statutory interpretation issue. It held that Kansas law does not require the state name to be clearly legible on license plates, except as it appears on registration decals. The court found that the lower courts had misapplied the statute by treating the obscured state name as a violation. The Supreme Court reversed the decisions of both the district court and the Court of Appeals on this issue and remanded the case for further proceedings consistent with its interpretation of the statute. View "State v. Beck " on Justia Law

A prospective employee applied for a position as an occupational therapist with a rehabilitation company, which required COVID-19 vaccination as a condition of employment. The applicant requested a religious exemption, submitting a written statement and a supporting letter from a friend citing religious objections to vaccines developed with fetal cell lines. The company questioned the applicant about her vaccination history and, finding her responses insufficiently sincere, denied the exemption and rescinded the job offer. The applicant filed a complaint with the Kansas Department of Labor, which found the company had violated Kansas law by inquiring into the sincerity of her religious beliefs.The company sought judicial review in the Johnson District Court, which reversed the agency’s decision. The district court held that the relevant Kansas statute, which prohibits employers from inquiring into the sincerity of an employee’s religious beliefs when considering COVID-19 vaccine exemptions, was preempted by federal law—specifically, the federal Vaccine Mandate for Medicare and Medicaid providers and Title VII of the Civil Rights Act. The district court also found the Kansas statute violated due process because it lacked a rational basis.On appeal, the Supreme Court of the State of Kansas reviewed the case de novo. The court held that the federal Vaccine Mandate and Title VII do not expressly or impliedly preempt the Kansas statute, because federal law permits but does not require employers to inquire into religious sincerity. The court further held that the Kansas law does not violate due process, as it is rationally related to the legitimate state interest of protecting religious liberty and provides adequate procedural protections. The Supreme Court of Kansas reversed the district court’s judgment and remanded the case for further proceedings. View "Powerback Rehabilitation v. Dept. of Labor" on Justia Law

The case concerns a defendant who murdered his girlfriend and their four-year-old daughter in their home. After committing the murders, he disposed of the bodies in separate locations, attempted to clean the crime scene, and then falsely reported the victims as missing to the police. Initially charged with capital murder, the defendant ultimately entered a plea agreement, pleading guilty to two counts each of felony murder and aggravated kidnapping. The plea allowed both parties to argue sentencing, present evidence of aggravation, and permitted the court to decide whether sentences would run concurrently or consecutively.The District Court of Ford County, Kansas, after considering testimony, victim impact statements, and other evidence, imposed consecutive hard 25-year sentences for the felony murders, with the aggravated kidnapping sentences to run concurrently. The court also assessed mandatory fees and stated its intent to waive any nonmandatory fees. However, the sentencing journal entry included both a domestic violence special program fee and a DNA database fee. The defendant appealed, arguing that the consecutive sentences were an abuse of discretion and that the nonmandatory fees were improperly imposed.The Supreme Court of the State of Kansas reviewed the case. It held that the district court did not abuse its discretion in imposing consecutive sentences, as the decision was reasonable given the aggravating circumstances. The court found that the domestic violence special program fee was erroneously imposed contrary to the court’s stated intent and must be vacated. The court also held that the domestic violence designation was supported by the record, but the required domestic violence assessment was not ordered and must be addressed on remand. The assessment of the DNA database fee was affirmed, as there was no specific finding of indigency. The judgment was affirmed in part, vacated in part, and remanded with directions. View "State v. Peterson " on Justia Law

The defendant killed his wife in the early morning hours after violating a protective order that required him to stay away from her residence. He had consumed a significant amount of alcohol throughout the previous day and provided conflicting accounts of the events leading to the killing, initially telling police he acted out of spite and “blacked out,” and later testifying at trial that the stabbing was accidental during a struggle. Forensic evidence showed multiple stab wounds and no signs of a struggle. After the killing, the defendant disposed of the body and took steps to prevent the children from seeing the scene.The State charged the defendant in the Riley District Court with premeditated first-degree murder, aggravated burglary, and violation of a protective order. At trial, the defendant requested jury instructions on voluntary intoxication and lesser included offenses of reckless homicide, which the district court denied. The jury convicted him on all counts. At sentencing, the district court pronounced sentences for the non-murder counts but failed to pronounce a sentence for the premeditated first-degree murder conviction. The defendant appealed directly to the Supreme Court of the State of Kansas, raising issues regarding jury instructions, prosecutorial error, and sentencing.The Supreme Court of the State of Kansas held that the district court erred by failing to give a voluntary intoxication instruction and by not considering the minimum evidence required for such an instruction. The court also found error in the prosecutor’s use of “we know” statements regarding contested facts. However, the court concluded that these errors, considered cumulatively, did not deprive the defendant of a fair trial given the overwhelming evidence of premeditation and intent. The court affirmed the convictions but remanded the case to the district court to pronounce a sentence for the premeditated first-degree murder conviction. View "State v. Bobian " on Justia Law

Two minor children were removed from their parents’ care after their father was incarcerated for felony convictions and their mother was unable to care for them due to drug addiction and homelessness. The children were placed in foster care after the Kansas Department for Children and Families determined that neither parent could provide adequate care. The father, while incarcerated, had limited contact with the children and did not complete most tasks in the reintegration plan, citing the constraints of his imprisonment. The children exhibited significant behavioral and emotional issues while in foster care, and potential placement with a maternal grandmother was being considered.The Leavenworth County District Court adjudicated the children as in need of care and, after 16 months without progress toward reintegration, found both parents unfit. The court based its finding regarding the father on his felony conviction and imprisonment, failure of reasonable efforts by agencies to rehabilitate the family, and failure to carry out a reasonable reintegration plan. The court concluded that the father’s unfitness was unlikely to change in the foreseeable future and that termination of parental rights was in the children’s best interests, given their need for permanency and the availability of a stable placement with a relative.The Kansas Court of Appeals affirmed the district court’s decision, focusing primarily on the father’s imprisonment as a statutory ground for unfitness and agreeing that the unfitness was unlikely to change soon. The Supreme Court of the State of Kansas reviewed the case and held that clear and convincing evidence supported the findings of unfitness and that the conduct or condition rendering the father unable to care for his children was unlikely to change in the foreseeable future. The court also held that the district court did not abuse its discretion in determining that termination was in the children’s best interests. The judgments of both lower courts were affirmed. View "In re K.W.D." on Justia Law

In 1994, the defendant was convicted of over 60 offenses, including two counts of first-degree murder, stemming from a series of burglaries in 1993 during which two residents were killed. After being shot by a resident during a burglary, the defendant fled, leaving behind gloves and a tire iron—later linked to the murders—and was subsequently arrested. Police recovered additional items, including blood-stained shoes and jeans, some of which the defendant admitted were his, though he claimed the blood was his own. The defendant denied ownership of the gloves and tire iron, but testimony connected him to those items. No DNA testing was performed on these items at the time of trial.Years after his conviction, the defendant filed a motion under K.S.A. 21-2512 seeking postconviction DNA testing of several pieces of evidence, arguing that modern testing could yield exculpatory results. The Geary District Court appointed counsel and ordered the evidence, which had been poorly stored for decades, to be evaluated by the Kansas Bureau of Investigation (KBI). The KBI determined that the condition of the evidence—due to improper storage, possible contamination, and degradation—meant that any DNA testing would likely be inconclusive. After an evidentiary hearing, the district court denied the motion, finding there was no reasonable scientific certainty that testing would yield accurate or exculpatory results.The Supreme Court of the State of Kansas reviewed the district court’s decision, applying a bifurcated standard of review: factual findings were reviewed for substantial competent evidence, and legal conclusions were reviewed de novo. The court held that K.S.A. 21-2512(c) does not require DNA testing based solely on an allegation that it could produce exculpatory evidence; courts must assess whether testing could actually yield such evidence. Because the evidence was too degraded to produce meaningful results, the denial of DNA testing was affirmed. View "State v. Holt " on Justia Law

After the death of Roxine Poznich in 2020, her revocable living trust became the subject of a dispute among her five children, who were named as beneficiaries. Sarah Tharrett, one of the children, was appointed successor trustee. David Everett, another child, challenged Sarah’s role and actions as trustee, first by suing for her removal (which was dismissed), and later by objecting to the final trust accounting and distribution. While all other beneficiaries approved the final accounting, David’s objections prevented the trust from being closed. Sarah then filed a declaratory action seeking court approval to distribute the trust assets and requested attorney fees due to David’s conduct.The Bourbon District Court resolved the matter by closing the trust, releasing Sarah from her duties, ordering distribution of the remaining assets, and awarding $4,000 in attorney fees against David’s share. David appealed but accepted his distribution check. Sarah filed a notice of acquiescence, arguing that David’s acceptance of the distribution barred his appeal. The Kansas Court of Appeals agreed, dismissing the appeal for lack of subject matter jurisdiction due to acquiescence, and denied Sarah’s request for appellate attorney fees, reasoning it lacked jurisdiction to consider the fee request.The Supreme Court of the State of Kansas reviewed the case. It held that due process violations only void a judgment if they so undermine personal jurisdiction that the party is denied any meaningful opportunity to be heard, which was not the case here. The court affirmed that a trust beneficiary who accepts a distribution cannot later challenge the amount on appeal, as the benefits are inseparable from any additional claims. The court also clarified that appellate courts retain jurisdiction to award attorney fees even if the appeal is dismissed for acquiescence. The Supreme Court affirmed the dismissal of David’s appeal and awarded Sarah $11,320 in appellate attorney fees. View "Tharrett v. Everett " on Justia Law

In November 2016, D.J., then 15 years old, was involved in a marijuana transaction that resulted in the shooting death of J.S. The State charged D.J. with felony murder, aggravated robbery, and possession of marijuana. D.J. agreed to plead no contest in exchange for the case being designated as an extended jurisdiction juvenile prosecution (EJJP) rather than being tried as an adult. The court sentenced D.J. to a juvenile correctional facility until he was 22 years, 6 months old, with an adult sentence of life without parole for 25 years for the felony murder count, among other penalties, stayed as long as D.J. complied with his juvenile sentence.In October 2021, D.J. was released on conditional release but was later found in a vehicle with firearms and marijuana, and in July 2022, he was caught driving without a license and possessing marijuana. The State moved to revoke D.J.'s juvenile sentence, and the district court found that D.J. had violated the conditions of his juvenile sentence by possessing firearms and marijuana and eluding law enforcement.The Kansas Supreme Court reviewed the case and affirmed the district court's decision. The court held that substantial competent evidence supported the revocation of D.J.'s juvenile sentence. The court also held that under K.S.A. 38-2364, the district court was required to revoke the juvenile sentence and impose the adult sentence upon finding a violation of the juvenile sentence. The court rejected D.J.'s arguments that the district court had discretion to continue the stay of the adult sentence and that the district court could modify the adult sentence under K.S.A. 22-3716.The court also dismissed D.J.'s constitutional proportionality claims, stating that case-specific challenges could not be raised for the first time on appeal and that D.J. failed to comply with Supreme Court Rule 6.02(a)(5) for his categorical challenge. Finally, the court declined to review D.J.'s ineffective assistance of counsel claim due to the lack of a Van Cleave hearing and insufficient factual development in the record. View "In re D.J. " on Justia Law

Luis Alvarado-Meraz was convicted of capital murder for the shooting deaths of his twin brother, Manuel, and Manuel's wife, Lucero Rodriguez. On the day of the incident, Alvarado-Meraz had arguments with Manuel and later texted friends and his mother, indicating distress and claiming he had shot Manuel. He was arrested the following day. The crime scene investigation revealed that both victims were shot multiple times, and the evidence suggested the shooter fired from a specific area in the apartment.In the Sedgwick District Court, Alvarado-Meraz raised three claims of error on appeal: violation of his right to be present during jury deliberations, prosecutorial error during closing arguments, and the denial of a jury instruction on voluntary manslaughter. The district court denied his motion for a new trial, and a senior judge later affirmed this decision, concluding that there was no proof of a violation of his right to be present during a critical stage of the trial.The Kansas Supreme Court reviewed the case and applied an abuse of discretion standard to the district court's decision. The court found no error in the district court's handling of the jury's question, as the evidence did not conclusively show that a question was asked or answered improperly. The court also found no prosecutorial error in the closing arguments, determining that the prosecutor's statements were reasonable inferences based on the evidence presented.Regarding the jury instruction on voluntary manslaughter, the court concluded that the instruction was not factually appropriate. The evidence did not support a finding of legally sufficient provocation that would justify a voluntary manslaughter instruction. The court affirmed Alvarado-Meraz's conviction, finding no reversible error in the issues raised on appeal. View "State v. Alvarado-Meraz " on Justia Law