Justia Kansas Supreme Court Opinion Summaries

The State filed a petition alleging that A.K., a three-year-old child, was in need of care. Both parents entered no contest statements, and the court found A.K. to be a child in need of care. The father later died, leaving the mother as the sole subject of the termination proceedings. The State filed a motion to terminate the mother's parental rights, and during a pretrial conference, the mother did not appear, but her attorney did. The court set a date for a "proffer trial" under K.S.A. 38-2248(f). At the proffer trial, the mother was absent, and her attorney objected to proceeding by proffer, leading the court to set a full trial date. The mother did not appear at the trial, and her substitute counsel did not object to proceeding by proffer. The court terminated the mother's parental rights based on the State's proffer of evidence.The Johnson District Court terminated the mother's parental rights based on the State's proffer of evidence. The mother appealed, arguing that the court had no authority to proceed by proffer because she had instructed her counsel to object. She also argued that K.S.A. 38-2248(f) violated procedural due process. The Court of Appeals affirmed the district court's decision, rejecting the mother's claims.The Kansas Supreme Court reviewed the case and held that the district court misapplied K.S.A. 38-2248(f) by terminating the mother's parental rights based on a proffer alone. The court clarified that while K.S.A. 38-2248(f) permits a proffer against an absent party who has not instructed their counsel to object, it does not allow the district court to make a finding of unfitness or terminate parental rights based solely on the proffer. The court reversed the judgments of both the Court of Appeals and the district court and remanded the case for further proceedings. View "In re A.K. " on Justia Law

Three individuals, including the defendant, set out to purchase marijuana from a seller and his associate. En route, two of them decided to rob the seller instead. At the seller’s apartment, the defendant held several people at gunpoint while his accomplice searched for drugs. During a struggle, the defendant shot the seller in the face. The defendant denied involvement, claiming an alibi corroborated by his wife. Physical evidence, including DNA and video footage, as well as eyewitness testimony, linked the defendant to the scene. The defendant was convicted by a jury of first-degree murder, aggravated robbery, conspiracy, aggravated assault, and criminal possession of a firearm.The Johnson District Court presided over the trial, where the defendant raised several issues: prosecutorial error due to the prosecutor’s use of “we know” statements during closing argument, the prejudicial display of graphic photographs, limitations on witness questioning, acceptance of a stipulation regarding prior convictions without a jury trial waiver, and alleged speedy trial violations due to COVID-19 delays. The district court admitted the stipulation, allowed the display of photographs, and sustained objections to certain defense questions. The defendant was sentenced to a hard 25 years for felony murder plus additional consecutive and concurrent terms.The Supreme Court of the State of Kansas reviewed the case. It held that the prosecutor’s “we know” statements regarding contested facts constituted error, but found the errors harmless beyond a reasonable doubt given the strength of the evidence. The court ruled that the length of time admitted evidence is displayed is within the trial judge’s discretion and found no abuse of discretion here. It determined that the defense failed to preserve the issue regarding excluded witness testimony. The court found constitutional error in accepting the stipulation without a jury trial waiver but held it was harmless. COVID-19-related delays were weighed neutrally in the speedy trial analysis, and no violation was found. The convictions were affirmed. View "State v. Cherry " on Justia Law

The case concerns a defendant who pleaded guilty to the premeditated murders of his mother and stepfather. In December 2021, he forced entry into their home, using a stolen firearm to shoot his mother six times and his stepfather four times. The defendant did not contest his responsibility for the crimes. Prior to sentencing, he presented evidence of severe mental illness, a troubled upbringing, and his acceptance of responsibility, seeking more lenient sentences based on these mitigating factors.The Bourbon District Court considered the defendant’s request for concurrent “hard 25” sentences, supported by expert testimony regarding his mental health and background. However, the court found that, while there were mitigating circumstances, they did not rise to the level of “substantial and compelling reasons” required to depart from the statutory “hard 50” sentence for premeditated first-degree murder. The court imposed two consecutive hard 50 sentences, emphasizing the brutal and premeditated nature of the crimes and the impact on the victims’ family. The defendant appealed directly to the Supreme Court of the State of Kansas, arguing that the district court abused its discretion in both the length and the consecutive nature of the sentences.The Supreme Court of the State of Kansas reviewed both sentencing decisions for abuse of discretion. The court held that the district court acted within its lawful discretion in declining to depart from the hard 50 sentences and in ordering the sentences to run consecutively. The court found that the mitigating evidence did not compel a lesser sentence given the facts of the case, and that the decision to impose consecutive sentences was reasonable in light of the gravity of the offenses. The defendant’s sentences were affirmed. View "State v. Mitchell " on Justia Law

Dennis O. Haynes III, serving a life sentence for first-degree murder, filed a motion requesting access to the warrants and their supporting materials in his criminal case. The district court granted him partial relief, allowing access to his arrest warrant and supporting affidavit but denying access to any search-warrant materials.Haynes initially pleaded guilty to multiple charges, including first-degree murder, in 2014 and was sentenced to life imprisonment without parole for 20 years. Nine years later, he filed a habeas corpus motion alleging ineffective assistance of counsel, which was refiled as a separate civil case. Subsequently, Haynes filed a postconviction motion in his criminal case requesting the probable-cause affidavits and all warrants. The district court denied this motion, but upon reconsideration, granted access to the arrest-warrant affidavit while denying access to search-warrant materials.The Kansas Supreme Court reviewed the case and found that K.S.A. 22-2302(b) and K.S.A. 22-2502(d) grant defendants a personal right to access affidavits or sworn testimony supporting arrest and search warrants, respectively, but do not address access to the warrants themselves. The court affirmed the district court's order granting Haynes access to the arrest-warrant affidavit but reversed the order denying access to search-warrant affidavits. The case was remanded with instructions to produce any search-warrant affidavits upon receipt of the necessary fee for production. View "State v. Haynes " on Justia Law

A three-year-old child, C.V., died in February 2019 while in the care of his mother’s domestic partner, Uraquio Arredondo, in Ulysses, Kansas. On the day of the incident, C.V. was behaving normally until left alone with Arredondo. Later that day, Arredondo called 911, reporting that C.V. had been in an accident. Emergency responders found C.V. unresponsive with extensive bruising. Medical examinations revealed that C.V. died from multiple blunt force injuries, including a fresh skull fracture and internal bleeding, with evidence of both recent and older injuries. Testimony from the daycare provider and C.V.’s father indicated prior signs of abuse, with C.V. attributing some injuries to Arredondo.The State charged Arredondo with felony murder and child abuse. He waived his right to a jury trial, and the Grant District Court judge found him guilty on both counts, imposing a life sentence for murder and a consecutive sentence for child abuse. During the investigation, law enforcement entered Arredondo’s residence three times without a warrant. Arredondo challenged the admissibility of evidence from the second and third entries, arguing lack of valid consent and coercion. He also sought to suppress his statements to law enforcement, claiming they were involuntary and made without Miranda warnings, but he had not objected to their admission at trial.The Supreme Court of the State of Kansas reviewed the case. It held that the second and third entries into the residence were lawful because Arredondo voluntarily consented to both searches, and the police lawfully secured the home based on probable cause. The court also found that Arredondo failed to preserve his challenge to the admissibility of his statements for appellate review. Finding no error, the court affirmed Arredondo’s convictions. View "State v. Arredondo " on Justia Law

Brian Beck was driving on Interstate 70 when a Geary County sheriff's deputy noticed that a frame around Beck's license plate partially obstructed the state name. The deputy executed a traffic stop, during which Beck appeared nervous and provided an odd explanation for his travel route. The deputy called for canine support, and the dog alerted to the presence of drugs. Beck consented to a search, and deputies found methamphetamine in his car. Beck was charged with possession of methamphetamine with intent to distribute, possessing a controlled substance without a drug tax stamp, and interference with law enforcement.The Geary District Court denied Beck's motion to suppress the evidence obtained from the search, ruling that the partial obstruction of the state name on the license plate justified the traffic stop. Beck was found guilty on all counts by a jury. The Kansas Court of Appeals affirmed the district court's decision, agreeing that the partial obstruction of the state name constituted a violation of Kansas law, thus justifying the stop.The Kansas Supreme Court reviewed the case and reversed the lower courts' decisions. The court held that Kansas law does not require the state name on a license plate to be clearly legible, only the alphanumeric display and registration decal. Therefore, the partial obstruction of the state name did not provide reasonable suspicion for the traffic stop. The court reversed Beck's convictions based on the evidence obtained during the search and remanded the case to the district court for a new hearing to determine if there were other valid grounds for the stop and seizure. View "State v. Beck " on Justia Law

Brenda Zaragoza fell in the parking lot of a Johnson County public library, resulting in serious injuries. She sued the Johnson County Board of Commissioners, alleging negligence for failing to mitigate the presence of a storm drain and warn of the change in elevation between the curb and the parking surface. The district court granted summary judgment for the County, citing recreational use immunity under the Kansas Tort Claims Act (KTCA), which bars negligence claims arising from the use of public property intended for recreational purposes unless gross and wanton negligence is involved. The court also denied Zaragoza's motion to amend her petition to add a claim of gross and wanton negligence.The Kansas Court of Appeals affirmed the district court's decision, holding that the library's recreational use immunity applied and that the district court did not abuse its discretion in denying Zaragoza's untimely motion to amend her petition. Zaragoza then petitioned for review, raising both issues. After the petition was granted, she filed a supplemental brief raising a new constitutional argument, which was not considered because it was not presented in her petition for review or before the lower courts.The Kansas Supreme Court upheld the lower courts' decisions. The court declined to consider Zaragoza's unpreserved constitutional challenge. It affirmed the district court's grant of summary judgment, agreeing that the library's parking lot fell under the recreational use immunity provision of the KTCA. The court also affirmed the district court's denial of Zaragoza's motion to amend her petition, finding no evidence of gross and wanton negligence by the County. The court concluded that the library is public property intended for recreational purposes and that the parking lot is integral to its function, thus qualifying for immunity under the KTCA. View "Zaragoza v. Board of Johnson County Comm'rs " on Justia Law

A man was convicted of capital murder for the deaths of his girlfriend and her unborn child. The case against him was largely circumstantial. He reported finding the victim shot in her home, cooperated with police, and provided an account of his whereabouts, supported by his grandmother. The investigation included analysis of surveillance footage, U-Haul rental records, cell phone data, and forensic evidence, but no direct evidence placed him at the scene. The prosecution’s theory relied on the timing and mileage of a rented U-Haul, similarities between shell casings found at the crime scene and at a friend’s house, and the defendant’s purchase of a firearm and ammunition. The defense pointed to gaps in the evidence, alternative suspects, and the lack of direct forensic links.The Johnson District Court admitted some of the defendant’s statements to police, excluded certain ballistics testimony, and barred evidence of the victim’s past fears of an ex-boyfriend. After a three-week trial, a jury found the defendant guilty, and he was sentenced to life without parole. On appeal, the defendant argued that the prosecutor repeatedly violated the court’s order in limine by discussing excluded ballistics evidence and improperly asserted as fact that disputed evidence was undisputed, among other claims.The Supreme Court of the State of Kansas found multiple instances of prosecutorial error, including repeated violations of the order in limine and improper statements during closing argument that conveyed the prosecutor’s opinion on disputed facts. The court held that these errors were not harmless, given the circumstantial nature of the evidence and the meaningful gaps in the State’s case. Applying the constitutional harmlessness standard, the court concluded there was a reasonable possibility the errors contributed to the verdict. The conviction was reversed and the case remanded for further proceedings. View "State v. Wash " on Justia Law

Jason W. Phipps pled no contest to two felonies and two misdemeanors in 2022. His presentence investigation report calculated a criminal history score of B, which he contested, arguing that his 2010 conviction for criminal threat should not be counted due to a ruling in State v. Boettger that struck down reckless criminal threat as unconstitutional. The district court used the modified categorical approach and concluded that Phipps' conviction was for the intentional version of criminal threat, thus maintaining the B score for sentencing.The Kansas Court of Appeals reviewed the case while the United States Supreme Court issued Counterman v. Colorado, which held that a reckless mens rea is sufficient for a criminal threat conviction. The Court of Appeals determined that Counterman overruled Boettger, making it irrelevant whether Phipps' conviction was for reckless or intentional criminal threat, and affirmed his sentence.The Kansas Supreme Court granted Phipps' petition for review. During the review, Phipps completed his sentence, leading the court to question whether the case was moot. After further briefing, the court concluded that Phipps' release rendered the issues moot and overruled the precedent set in State v. Roat, which allowed for review of moot issues under certain exceptions. The court held that once an issue is determined to be moot, jurisdiction is extinguished, and no prudential exceptions apply. Consequently, Phipps' appeal was dismissed as moot, and the court did not address the merits of the Counterman decision. View "State v. Phipps " on Justia Law

Brian Stubbs was convicted of criminal use of a weapon and interference with law enforcement after an incident where he stabbed Edward McCutcheon with a large kitchen knife. Stubbs arrived uninvited at McCutcheon's apartment, leading to a fight. McCutcheon was seriously injured, and Stubbs fled the scene. Police pursued Stubbs, who ignored commands to stop, leading to his arrest.The Douglas District Court convicted Stubbs of criminal use of a weapon and interference with law enforcement. Stubbs appealed, arguing that the statute under which he was convicted was unconstitutionally vague and that there was insufficient evidence to support his conviction for interference with law enforcement. The Kansas Court of Appeals affirmed the district court's decision, holding that Stubbs lacked standing to challenge the statute's vagueness because he did not show it was vague as applied to his conduct.The Kansas Supreme Court reviewed the case and held that Stubbs had standing to bring an arbitrary-enforcement challenge to the statute. The court explained that such challenges are inherently facial because they dispute the legislature's authority to enact the statute at all. The court found that Stubbs' conviction under the allegedly void statute presented a concrete injury, satisfying the standing requirements.On the merits, the Kansas Supreme Court held that the statute's prohibition on possessing a "dangerous knife" with intent to use it "unlawfully against another" provided adequate enforcement guidelines. The court concluded that the statute did not invite arbitrary or discriminatory enforcement. Additionally, the court found sufficient evidence to support Stubbs' conviction for interference with law enforcement, as the jury could reasonably conclude that Stubbs knowingly obstructed the officer's duties. The court affirmed the judgments of both the Court of Appeals and the district court. View "State v. Stubbs " on Justia Law