Justia Kansas Supreme Court Opinion Summaries
EagleMed v. Travelers Insurance
In this consolidated workers compensation appeal arising from disputes between EagleMed, LLC, a critical care transportation service, and Travelers Insurance, a workers compensation insurance carrier, the Supreme Court reversed the court of appeals' judgment directing the Workers Compensation Appeals Board to dismiss this proceeding, holding that remand was required.49 U.S.C. 41713(b)(1) prohibits states from enacting or enforcing any law related to a service of an air carrier providing air transportation. Kan. Stat. Ann. 44-510i(c)(2) requires the Director of the Division of Workers Compensation to oversee health care provider services to ensure charges are "fair, reasonable, and necessary." At issue was the phrase "usual and customary charges." The Board decided it lacked jurisdiction to determine the reasonableness of air ambulance charges that would reduce the amount owed, made no factual determination whether the disputed billings were "usual and customary charges," and ordered Travelers to pay in full. The court of appeals reversed. The Supreme Court vacated the panel's decision and the Board's order that Travelers pay EagleMed in full and remanded the case for the Board to decide whether the charges were "usual and customary," holding that the Board will need to interpret this term in a manner reflecting both federal law and the state's legislative purposes. View "EagleMed v. Travelers Insurance" on Justia Law
Posted in:
Civil Procedure, Government & Administrative Law
State v. Claiborne
The Supreme Court affirmed the decision of the district court summarily denying Defendant's pro se motion to correct an illegal sentence, holding that the district court did not err.Defendant was sentenced to life imprisonment, subject to the possibility of parole after fifteen years, for first-degree murder and related crimes. Defendant later moved to correct an illegal sentence, arguing, among other things, that his sentence was disproportionate punishment. The district court summarily denied the motion. The Supreme Court affirmed, holding that Defendant's sentence was not ambiguous and was not illegal. View "State v. Claiborne" on Justia Law
Posted in:
Criminal Law
In re L.L.
The Supreme Court dismissed Grandparents' appeal in this case involving a parentage issue and the enforceability of a "co-parenting agreement," holding that the current posture of this case left Grandparents without standing in their personal capacities.Grandparents, as next friends of L.L. and in their personal capacities, filed a petition for determination of paternity and grandparent rights and seeking joint custody of L.L. The district court found that it had jurisdiction of L.L., Grandparents, and Mother and concluded (1) joint legal custody is only between parents and not between a parent and grandparents, and (2) the purported co-parenting agreement did not fit within grandparent visitation rights. The Supreme Court dismissed Grandparents' appeal, holding that Grandparents lost standing when this appeal narrowed down to their personal claim. View "In re L.L." on Justia Law
Posted in:
Family Law
State v. Gutierrez-Fuentes
The Supreme Court affirmed Defendant's convictions for aggravated battery, aggravated burglary, and criminal threat, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the court of appeals panel abused its discretion in entertaining Defendant's constitutional speedy trial claims required factual development out of the reach of an appellate court; (2) the evidence was sufficient to support Defendant's aggravated burglary conviction; and (3) the district court erred by admitting out-of-court statements of an interpreter over defense hearsay objections, but the erroneous ruling on the hearsay objection was harmless. View "State v. Gutierrez-Fuentes" on Justia Law
Posted in:
Criminal Law
State v. Garcia
The Supreme Court affirmed Defendant's conviction for premeditated first-degree murder and his sentence of life without the possibility of parole for fifty years, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the district court did not err or abuse its discretion in denying Defendant's motion for a venue change; (2) the autopsy photographs admitted at trial were relevant, and the district court did not abuse its discretion in concluding that they were not unduly prejudicial; and (3) the district court did not err when it declined Defendant's request for an instruction on voluntary manslaughter. View "State v. Garcia" on Justia Law
Posted in:
Criminal Law
State v. Fowler
The Supreme Court affirmed the sentence imposed following Defendant's plea of guilty to two counts of premeditated first-degree murder and one count of felony theft, holding that the district court did not abuse its discretion in sentencing Defendant.Defendant pleaded guilty to two counts of premeditated intentional murder and one count of theft. The trial court sentenced him to two consecutive hard fifty life terms for the murders. On appeal, Defendant argued that the district court erred in denying his request for a departure sentence, essentially challenging the decision's reasonableness. The Supreme Court affirmed, holding that the district court did not abuse its discretion by denying Defendant's departure motion. View "State v. Fowler" on Justia Law
Posted in:
Criminal Law
Doe v. M.J.
In this interlocutory appeal, the Supreme Court affirmed the opinion of the court of appeals affirming the judgment of the district court denying Defendants' motions for dismissal and summary judgment, holding that there was no error.Plaintiff brought this action alleging that Father M.J., a priest, and the Roman Catholic Archdiocese of Kansas City alleging various torts based on sexual abuse from M.J. when Plaintiff was a child. Defendants filed motions for dismissal and summary judgment, arguing that Plaintiff's claims were time barred. The district court denied the motions, and the court of appeals affirmed. The Supreme Court affirmed, holding that disputed questions of material fact remained. View "Doe v. M.J." on Justia Law
Posted in:
Personal Injury
State v. Tafolla
The Supreme Court affirmed the judgment of the district court revoking Defendant's probation and order him to serve his original prison sentence, holding that the district court's revocation of Defendant's probation adhered to the statutory framework in Kan. Stat. Ann. 22-3716(c)(9)(B).Defendant pleaded guilty to failure to register under the Kansas Offender Registration Act. After Defendant violated his probation, the district court revoked his probation and ordered him to serve the original prison sentence. On appeal, Defendant argued that the district court lacked the authority to revoke his probation without imposing the required immediate sanctions. The Supreme Court affirmed, holding that the district court did not abuse its discretion by bypassing immediate sanctions and imposing Defendant's original prison sentence. View "State v. Tafolla" on Justia Law
Posted in:
Criminal Law
State v. Rozell
In this criminal case, the Supreme Court reversed the decisions of the district court and the court of appeals concluding that Kansas did not have "proximate result" jurisdiction under Kan. Stat. Ann. 21-5106, holding that the lower courts erred in interpreting and applying section 21-5106.At issue was whether Kansas had territorial jurisdiction to prosecute Defendant for insurance fraud and making a false information where Defendant committed no acts related to those charges while physically in the state. The district court dismissed the case for lack of jurisdiction. The court of appeals affirmed. The Supreme Court reversed, holding that the State presented sufficient evidence to establish probable cause that Defendant's actions caused a consequence or effect in Kansas close enough in time or cause to the alleged criminal acts to qualify as a proximate result allowing Kansas to exercise jurisdiction. View "State v. Rozell" on Justia Law
Posted in:
Civil Procedure, Criminal Law
L. Ruth Fawcett Trust v. Oil Producers Inc. of Kansas
In this second appeal in a class action case alleging a breach of the implied duty to market gas and underpaid royalties the Supreme Court affirmed the decision of the district court denying a class's motion to amend its petition and granting partial summary judgment for Oil Producers Inc. of Kansas (OPIK) on the class's breach of duty to market gas as it related to the marketable condition rule, holding that there was no error.In the first appeal in this case, the Supreme Court listed the conditions under which a well operator may satisfy its duty to market raw gas production. On remand, the class of royalty owners moved to amend the petition to clarify that its original claim of breach of implied duty to market implicated the implied duty of good faith and fair dealing. The district court denied the motion and granted summary judgment for OPIK. The Supreme Court affirmed, holding (1) the law of the case doctrine precluded thecClass from relitigating its claim that OPIK breached its implied duty of faith and fair dealing as alleged in the motion to amend the petition; (2) the class was not entitled to prejudgment interest; and (3) the lower courts appropriately denied OPIK's statute of limitations defense to the class's conservation fee claim. View "L. Ruth Fawcett Trust v. Oil Producers Inc. of Kansas" on Justia Law
Posted in:
Class Action, Energy, Oil & Gas Law