Justia Kansas Supreme Court Opinion Summaries

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

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

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

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

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

The Supreme Court affirmed Defendant's convictions of felony possession of methamphetamine, misdemeanor possession of drug paraphernalia with intent to use, and misdemeanor theft, holding that the district court did not err in denying Defendant's motion to suppress.Defendant was detained at Walmart for trying to leave the store without paying for merchandise. Defendant was arrested and taken to jail, where a booking deputy conduct an inventory search of Defendant's possessions. Upon discovering illicit drugs the deputy did a strip search of Defendant's person, discovering more illicit drugs. Defendant moved to suppress the drugs and paraphernalia based on an illegal misdemeanor arrest. The motion was denied, and Defendant was convicted. On appeal, Defendant argued that the evidence should have been suppressed because the officer illegally arrested her rather than issuing her a notice to appear. The Supreme Court affirmed, holding that the officer had probable cause to believe Defendant committed misdemeanor theft and would not be apprehended. View "State v. Goodro" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motions filed under Kan. Stat. Ann. 60-1507 and Kan. Stat. Ann. 22-3504, holding that Defendant's section 60-1507 motion was untimely and successive and that Defendant's sentence was not illegal.In 2003, Defendant was convicted by a jury of first-degree murder and sentenced to a hard fifty life sentence. Since his conviction, Defendant filed multiple collateral attacks on his sentence and conviction, all of which were unsuccessful. In the motions at issue on appeal, Defendant alleged that his sentence was unconstitutional under Apprendi v. New Jersey, 530 U.S. 466 (2000) and that this Court's failure to correct his sentence violated Kan. Stat. Ann. 21-6628(c). The district court denied both motions. The Supreme Court affirmed, holding that the district court did not err in denying the motions. View "Drennan v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to set aside a void judgment under Kan. Stat. Ann. 60-260(b)(4) and his motion to correct an illegal sentence under Kan. Stat. Ann. 22-3504, holding that Defendant's argument on appeal was not legally sound.Defendant, an inmate serving a life sentence for first-degree felony murder, filed a motion to set aside a void judgment and a motion to correct an illegal sentence, arguing that his sentence was void and illegal because the State initially charged him with an offense outside of the statute of limitations, depriving the district court of jurisdiction over all later proceedings. The Supreme Court affirmed, holding that the statute of limitations is not a jurisdictional bar, and therefore, the complaint was never void, and Defendant's sentence was not illegal. View "State v. Gleason" on Justia Law

The Supreme Court affirmed the decision of a panel of the court of appeals affirming the judgment of the district court granting summary judgment to the Kansas Workers Compensation Fund on the Fund's collateral action against Trademark, Inc., holding that there was no error.After Juan Medina received a workplace injury he sought compensation from his direct employer under the Kansas Workers Compensation Act, Kan. Stat. Ann. 44-501 et seq. Because the employer did not carry workers compensation insurance, Medina impleaded the Fund to obtain benefits. Thereafter, an ALJ awarded compensation to Medina, and the Fund paid Medina benefits. The Fund then filed this action under Kan. Stat. Ann. 44-532a against Trademark, the general contractor for whom Medina's employer was acting as a subcontractor at the time of the injury. The district court granted summary judgment to the Fund and denied attorney fees. The court of appeals panel affirmed. The Supreme Court affirmed, holding (1) the lower courts correctly interpreted section 44-532a as allowing the Fund to pursue an action against Trademark; but (2) the Fund was not entitled to attorney fees. View "Schmidt v. Trademark, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court entering judgment upon the jury's verdict and convicting Defendant of first-degree murder, aggravated battery, and criminal possession of a weapon, holding that Defendant received constitutionally effective assistance of counsel.After he was convicted, Defendant filed a post trial motion alleging several instances of ineffective assistance of trial counsel. The district court denied the motion after holding an evidentiary hearing. The Supreme Court affirmed, holding that the record showed that trial counsel (1) did not coerce Defendant or his witnesses to change their testimony about the events leading up to the murder; and (2) did not disregard the firearm expert's testimony regarding the functionality of the victim's gun. View "State v. Evans" on Justia Law