Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's sentence of death imposed in connection with his conviction for capital murder, holding that the sentence was not "imposed under the influence of passion, prejudice or any other arbitrary factor." See Kan. Stat. Ann. 21-6619(c)(1).Defendant was convicted of capital murder and sentenced to death. The Supreme Court affirmed the convictions but vacated the death sentencing, holding that the failure to sever the penalty phase violated Defendant's right to an individualized sentencing determination under the Eighth Amendment. However, in Kansas v. Carr, 477 U.S. 108 (2016), the United States Supreme Court held that the trial court's failure to Defendant's penalty phase did not implicate either the Eighth Amendment or the Due Process Clause. On remand, the Supreme Court addressed penalty phase issues that remained unresolved. The Court then affirmed Defendant's sentence, holding that Defendant received a fair trial and that any mitigating circumstances were insufficient to outweigh the aggravating circumstances. View "State v. Carr" on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendant's motion for a sentence modification under Kan. Stat. Ann. 21-6628(c) and denied Defendant's newly raised claim of an illegal sentence, holding that Defendant was not entitled to relief.Defendant was convicted of first-degree murder and sentenced to a hard forty sentence. Defendant later filed a pro se motion for sentence modification pursuant to Kan. Stat. Ann. 21-6628(c), which the district court denied. The Supreme Court affirmed the denial, holding (1) the district court did not err in denying Defendant's motion for sentence modification; and (2) Defendant's argument raised for the first time on appeal that his sentence was illegal because the sentencing court did not comply with a statutory direction to designate the aggravating circumstances in writing was without merit. View "State v. Bedford" on Justia Law

The Supreme Court affirmed Defendant's conviction for possession of methamphetamine for insufficient evidence, holding that the evidence was sufficient to support the conviction and that Defendant could not challenge the underlying search of the vehicle in which he was a passenger.On appeal, the court of appeals reversed Defendant's conviction of methamphetamine possession for insufficient evidence based on the parties' stipulation of facts. The Supreme Court reversed, holding that the court of appeals (1) erred in concluding that Defendant's conviction was not supported by sufficient evidence; and (2) correctly concluded that Defendant's status as a passenger did not confer standing for purposes of the Fourth Amendment to challenge the search of the car. View "State v. Scheuerman" on Justia Law

The Supreme Court reversed the portion of the district court's judgment declaring 2021 Senate Bill 40 invalid and unenforceable based on certain infirmities the court observed, holding that the district court erred by ignoring the constitutional avoidance doctrine and failing to abide by it.This case arose from a dispute regarding public school policies mandating face masks during the COVID-19 pandemic. After the Legislature passed S.B. 40 imposing substantive limits on COVID-19 mitigation measures adopted by other governmental entities Plaintiffs sued the Shawnee Mission School District challenging the district's mask policy. Plaintiffs asserted S.B. 40 as the only legal authority for their lawsuit. The district court dismissed the claims as moot and then ruled that S.B. 40 was unenforceable because it violated both due process and separation of powers. The Supreme Court reversed, holding that the district court erred in its analytical diversion into S.B. 40's constitutionality. View "Butler v. Shawnee Mission School District Board of Education" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, holding that the errors committed during Defendant's trial did not affect the jury's verdict.Specifically, the Supreme Court held (1) there was no error in the admission of an autopsy photograph; (2) the prosecutor erred in closing argument by repeatedly use the phrase "we know" before discussing controverted facts, but the error was harmless; (3) presuming that the district court erred in not instructing the jury on the limited purpose for which the judge admitted some evidence, the error did not affect the verdict; (4) there was no error when the district court listed the jury's choice of finding Defendant guilty before listing the option of not guilty on the verdict form; and (5) the cumulative errors in this case did not affect the outcome. View "State v. Alfaro-Valleda" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the district court's decision to revoke Defendant's probation, holding that the district court failed to follow the statutory graduated sanctions set out in Kan. Stat. Ann. 22-3716.Section 22-3716 requires judges, except under certain circumstances set forth in a bypass exception, to impose specified intermediate sanctions before revoking a defendant's probation. In the instant case, Defendant committed multiple probation violations and received sanctions on two prior occasions. After a third violation, a district court judge revoked Defendant's probation without mentioning the bypass exception. The Supreme Court remanded the case, holding that the harmless error analysis does not apply to the district court's failure to follow the statutory graduated sanctions set forth in section 22-3716. View "State v. Wilson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court's entry of summary judgment for First Security Bank (FSB) in its foreclosure action against David and Linsay Buehne, holding that that the Buehnes's challenges on appeal were unavailing.FSB brought this foreclosure action after the Buehnes failed to make payments on the commercial promissory note they executed with FSB. The district court granted summary judgment in favor of FSB. The court of appeals affirmed. The Supreme Court affirmed, holding that the court of appeals did not err in concluding that a specific contractual clause in the note waiving the defense of the statute of limitations in advance was not void as against public policy. View "First Security Bank v. Buehne" on Justia Law

The Supreme Court affirmed Defendant's convictions for felony murder, criminal discharge of a firearm at an occupied vehicle, and aggravated assault, holding that there was no reversible error in the proceedings below.At his first trial, Defendant was convicted of criminal discharge of a firearm at a vehicle and aggravated assault, but the jury deadlocked on Defendant's felony-murder charge. After a second trial on the remaining charge, Defendant was convicted of felony murder. The Supreme Court affirmed, holding (1) the district court properly instructed the second jury on felony murder; (2) the State committed prosecutorial error in the first trial when it improperly appealed to the passions of the community, but the district court's prompt instruction to disregard cured this error, and any other assumed prosecutorial error was harmless; (3) the district court did not err in either trial by failing to instruct the jury on the lesser included offense of discharge of a firearm from a roadway; (4) there was no error in the jury instructions; and (5) the cumulative effect of any error was harmless. View "State v. Rhoiney" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for first-degree felony murder, holding that Defendant's arguments on appeal were unavailing.Defendant was convicted of first-degree felony murder, criminal threat, and distribution of methamphetamine. On appeal, Defendant argued that insufficient evidence supported his felony murder conviction and that the district court violated his common-law right to a jury trial by making judicial findings of his prior convictions to establish his sentence. The Supreme Court affirmed, holding (1) the evidence was sufficient to establish beyond a reasonable doubt that Defendant was guilty of felony murder; and (2) Defendant's constitutional challenge to the Kansas Sentencing Guidelines Act failed. View "State v. Pearce" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of a federal district court granting summary judgment in favor of Defendants on Plaintiff's federal claims and declining to exercise supplemental jurisdiction over her state law claims, holding that the doctrine of res judicata did not prevent Plaintiff from bringing the state law claims in state court.Plaintiff sued the City of Wichita and one of its police officers in the United States District Court for the District of Kansas, alleging federal civil rights violations and state law tort claims. The federal district court granted summary judgment in favor of Defendants on the federal claims and declined to exercise supplemental jurisdiction over Plaintiff's state law claims. Plaintiff refiled her state law claims in Sedgwick County District Court, which held that Plaintiff's state law claims were barred by res judicata. The Supreme Court reversed, holding that when a federal court declines to exercise supplemental jurisdiction over state law claims and dismisses those claims without prejudice, there has been no final judgment on those state law claims, and res judicata does not preclude a litigant from bringing those claims in state court. View "Herington v. City of Wichita" on Justia Law