Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals to dismiss this appeal of a judgment of conviction, holding that the court of appeals correctly held that it lacked jurisdiction over Defendant's appeal.Defendant committed a felony while on probation for another felony conviction. The sentencing judge ordered Defendant to serve the presumptive sentence for his new conviction under the Kansas Sentencing Guidelines Act (KSGA), Kan. Stat. Ann. 21-6801 et seq., and ordered Defendant to serve his sentence consecutive to the sentence for the earlier crime. Defendant appealed, arguing that the sentencing judge should have applied Kan. Stat. Ann. 21-6819(a), which allows a judge to impose concurrent sentences if the term of imprisonment resulting from the application of Kan. Stat. Ann. 21-6606, which the judge applied in this case, would be manifestly unjust. The court of appeals dismissed the appeal. The Supreme Court affirmed, holding that the appellate court lacked jurisdiction to review the sentencing judge's decision applying section 21-6606 rather than section 21-6819(a). View "State v. Young" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to withdraw his plea of guilty to two counts of felony first-degree murder, holding that Defendant failed to prove manifest injustice in the circumstances of entering his guilty plea.Defendant pled guilty two two counts of felony first-degree murder, and the court sentenced him to two consecutive hard twenty-five life sentences. Defendant then filed his pro se motion seeking relief on a wide variety of grounds. The trial court denied relief. The Supreme Court affirmed, holding that any failures on the part of counsel to inform Defendant that compulsion is a defense to felony murder did not rise to the level of manifest injustice that would require a court to give him leave to withdraw his plea. View "State v. Hutto" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion to correct an illegal sentence under Kan. Stat. Ann. 22-3504 asserting that his sentence was unconstitutional, holding that the Legislature has foreclosed Appellant's ability to challenge the constitutionality of his sentence through the illegal sentence statute.Appellant was sentenced to three consecutive life sentences for multiple felonies he committed as a juvenile. Decades later, Appellant filed a pro se motion seeking relief under section 22-3504 and Kan. Stat. Ann. 60-1507. The district court denied the motion. The Supreme Court affirmed, holding that Appellant's challenges fell outside the narrow definition of an "illegal sentence" under section 22-3504, and Appellant abandoned any other claim for relief on appeal. View "State v. R.H." on Justia Law

The Supreme Court affirmed Defendant's convictions on three counts of first-degree premeditated murder, holding that Defendant was not entitled to relief on his two instructional error claims and his one prosecutorial error claim.Specifically, the Supreme Court held (1) any error committed by the trial court in failing to instruct the jury on both second-degree intentional murder and voluntary manslaughter as lesser included offenses was not reversible; (2) the prosecutor offered his personal opinion in using the rhetorical phrase "we know" during closing argument, but the error was not reversible; and (3) collectively, the one error and two assumed instructional errors did not produce the degree of prejudice necessary for reversal. View "State v. Douglas" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's postconviction motion to compel the production of records related to his criminal case, holding that there was no basis for the discovery Appellant requested.More than a decade ago, Appellant went through criminal proceedings that led to his conviction of first-degree premeditated murder. At issue was Appellant's "pro se and barebones" postconviction motion to compel production of records related to his criminal proceedings. The district court denied the motion. The Supreme Court affirmed, holding (1) there was no support for Appellant's theory that Kan. Stat. Ann. 22-3212 and 22-3213 apply to his motion for postconviction discovery; and (2) because Appellant cited no other basis for the requested discovery, the district court properly denied his motion to compel discovery. View "State v. Marks" on Justia Law

The Supreme Court dismissed this appeal concerning whether the Kansas Open Records Act (KORA), Kan. Stat. Ann. 45-215 et seq., requires a Kansas district court to make audio records of open court proceedings available for public inspection, holding that Appellant lacked standing.Appellant made a written request to listen to and copy digital audio recordings made during two public court hearings. Appellant was neither a party in the case nor counsel for any party. When Appellant was denied access to the recordings he sought declaratory and injunctive relief. The district court dismissed the claims, holding that the audio recordings were exempt from disclosure and that Appellant had no constitutional or common-law right to the recordings. The court of appeals reversed, holding (1) Appellant did not meet his burden to establish his standing; and (2) therefore, this Court and the court of appeals lacked jurisdiction over this appeal. View "Baker v. Hayden" on Justia Law

The Supreme Court affirmed Defendant's convictions for rape, criminal threat, sexual battery, and battery, holding that, even if Defendant was correct that rape is essentially a strict liability crime, he failed to establish that this would violate his due process rights.Before the Supreme Court, Defendant argued that the Kansas rape statute - and by extension the jury instruction mirroring the statute - effectively rendered rape a strict liability crime. The Supreme Court affirmed, holding that, even assuming Defendant was correct that Kan. Stat. Ann. 21-5503(e) effectively rendered rape a strict liability crime in Kansas, he failed to show that this was a violation of his right to due process or outside the legislature's authority to draft criminal laws. View "State v. Thomas" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals rejecting Defendant's challenge to the Kansas Sentencing Guidelines Act (KSGA), Kan. Stat. Ann. 21-6801, et seq., and affirming her conviction and sentence for two drug offenses, holding that the KSGA's method of determining a defendant's criminal history does not implicate the right to trial by jury guaranteed by section 5 of the Kansas Constitution Bill of Rights.In accordance with the KSGA, the district court judge imposed Defendant's sentence based, in part, on judicial findings he made regarding her criminal history. For the first time on appeal, Defendant argued that the KSGA violates section 5 because it allows the court to make criminal history findings for purposes of imposing a sentence, contrary to her right to a trial by jury. The court of appeals rejected Defendant's argument and affirmed. The Supreme Court affirmed, holding that the KSGA provisions authorizing a court to make criminal history findings for purposes of imposing a sentence do not violate section 5 because such judicial findings do not impair the traditional functions of the jury in criminal proceedings. View "State v. Albano" on Justia Law

The Supreme Court affirmed Defendant's conviction of identity theft, holding that an employee can commit identity theft by using the social security number of another to deceive an employer and induce the employer to rely on the deception and provide employment and its benefits.Defendant's conviction arose from allegations that he was using the social security number of someone else with the intent to defraud his employer so he could receive a benefit. Defendant appealed, arguing that there was insufficient evidence to support his conviction and that the identity theft statute is unconstitutionally vague. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the conviction; and (2) the identity theft statute is not unconstitutionally vague. View "State v. Valdiviezo-Martinez" on Justia Law

The Supreme Court reversed Defendant's conviction of one count of premeditated first-degree murder and one count of possession of methamphetamine with intent to distribute, holding that there was error in the jury instructions given during Defendant's trial.On appeal, Defendant argued that the trial court erred in allowing the homicide prosecution to proceed where he made an assertion of self-defense and that the trial court erred in concluding that an instruction on involuntary manslaughter was legally inappropriate. The Supreme Court reversed the murder conviction and remanded this case for further proceedings, holding (1) the State's case was sufficient to proceed with prosecution; and (2) it was error for the trial court to deny the requested instruction on involuntary manslaughter, and the error was prejudicial. View "State v. Nunez" on Justia Law