Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the district court dismissing M.M.'s claim seeking to recover compensation for his wrongful 226-day confinement to a juvenile corrections facility, holding that Kan. Stat. Ann. 60-5004 does not allow compensation for wrongful juvenile adjudications.A district magistrate judge found M.M. guilty of aggravated indecent liberties and sentenced him to two years' confinement at a juvenile corrections facility. Thereafter, a district court jury found M.M. not guilty of aggravated indecent liberties and released M.M. back to the custody of his mother. M.M. subsequently filed a petition for certificate of innocence under section 60-5004. The district court dismissed the petition. The Supreme Court affirmed, holding that the plain language of section 60-5004 unambiguously bars claimants from recovering for wrongful juvenile adjudications. View "In re M.M." on Justia Law

The Supreme Court affirmed the judgment of the district court reversing Defendant's conviction of aggravated battery, rape, and aggravated kidnapping on the grounds that a conflict of interest existed between Defendant and his counsel that adversely affected the representation.In his Kan. Stat. Ann. 60-1507 motion for relief from his convictions Defendant argued that his counsel had a personal and financial conflict of interest that adversely affected his performance in Defendant's case. The district court agreed and set aside Defendant's convictions without determining whether prejudice resulted from the conflict of interest. The Supreme Court affirmed, holding that Defendant's convictions must be reversed based on the financial conflict of interest of his trial counsel. View "Ellie v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Richard Quillen's petition to be placed in transitional release from his civil commitment as a sexually violent predator under the Kansas Sexually Violent Predator Act (KSVPA), holding that the jury instructions given at Quillen's transitional release hearing were constitutionally adequate.After a jury trial, the court found that Quillen's mental abnormality or personality disorder remainder such that he was not safe to be placed in transitional release. On appeal, Quillen argued that the district court erred when it denied his request for an instruction that the jury must find Quillen had serious difficulty controlling his behavior. The Supreme Court affirmed, holding (1) at a transitional release hearing, substantive due process requirements are satisfied when the jury instructions as a whole require the jury to necessarily and implicitly find the respondent continues to have serious difficulty controlling his dangerous behavior; and (2) the jury instructions in Quillen's case were constitutionally adequate under this standard. View "In re Care & Treatment of Quillen" on Justia Law

The Supreme Court affirmed the district court's summary dismissal of Defendant's motion to correct an illegal sentence, holding that the district court did not err.Defendant was convicted of first-degree murder, aggravated robbery, and conspiracy to commit robbery. Upon sentencing, the sentencing judge granted the State's request for an upward departure without the use of a jury. The Supreme Court affirmed the convictions on direct appeal, and the mandate issued on January 9, 1996. In his latest postconviction motion, Defendant argued that his upward departure sentence violated his due process rights under Apprendi v. New Jersey, 530 U.S. 466 (2000) and State v. Gould, 23 P.3d 801 (2001). The district court summarily dismissed Defendant's motion. The Supreme Court affirmed, holding that several factors precluded Defendant from pursuing relief through a motion for illegal sentence, including the fact that a motion for illegal sentence cannot serve as a vehicle for raising constitutional claims such as Defendant's Apprendi claim. View "State v. Hayes" on Justia Law

The Supreme Court affirmed Defendant's convictions for possession of marijuana, methamphetamine, and drug paraphernalia, holding that the trial court erred in admitting evidence that a syringe was found by police during a search that violated Defendant's Fourth Amendment rights but that the error was harmless.On appeal, the State conceded that the district court should have granted Defendant's motion to suppress on the syringe, admitting that the search incident to arrest exception for a warrantless search did not apply to this particular search. The court of appeals affirmed, accepting the State's concession that the syringe discovery was the product of an illegal search but without determining whether the evidence was harmless beyond a reasonable doubt. The Supreme Court affirmed, holding the court's admission of the syringe evidence was harmless beyond a reasonable doubt. View "State v. Thornton" on Justia Law

The Supreme Court ordered that F. William Cullins, a district judge in the Fourteenth Judicial District be suspended from his judicial duties in the state of Kansas for one year, concluding that the charges against Cullins were supported by clear and convincing evidence.After a hearing, the Commission on Judicial Qualifications found that Cullins had engaged in conduct that violated Canon 1, Rule 1.2 and Canon 2, Rules 2.3 and 2.8 the Kansas Code of Judicial Conduct. The Commission recommended that Cullins be disciplined for the violations by public censure and that the Supreme Court refrain from making any future appointment of Cullins as chief judge. The Supreme Court ordered that Cullins be suspended from his judicial duties for one year and that the suspension be stayed after sixty days provided that Cullins enters into an approved plan for training and counseling. View "In re Cullins" on Justia Law

The Supreme Court affirmed Defendant's convictions of premeditated first-degree murder and criminal possession of a weapon by a convicted felon but vacated the imposition of lifetime postrelease supervision as part of Defendant's sentence, holding that this portion of the sentence was erroneous.A jury convicted Defendant of both premeditated first-degree murder and criminal possession of a weapon by a convicted felon. The trial court sentenced him to a hard fifty life sentence for the murder and lifetime postrelease supervision for that charge. The Supreme Court affirmed in part and vacated in part, holding (1) the trial court did not err in denying Defendant's motion for mistrial; (2) the prosecutor's comments during opening statement did not constitute error; (3) the verdict from presented no error of law; and (4) the sentencing court had no authority to order a term of postrelease supervision. View "State v. Fraire" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court concluding that Mother's voluntary relinquishment of her child under Kan. Stat. Ann. 38-2268 was a legally authorized adjudication of Mother's parental rights, holding that Mother's relinquishment of parental rights was effective to terminate her parental rights.One of the primary issues on appeal was whether formal written acceptance by the Kansas Department for Children and Families (DCF) is required in order for a parent's relinquishment of parental rights to DCF to be valid. The Supreme Court held (1) there was substantial, competence evidence to support a finding that Mother's relinquishment of parental rights to her child was valid, knowingly made, and effective to terminate her parental rights; and (2) Mother was afforded the procedural due process to which she was entitled. View "In re P.R." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction for failure to register under the Kansas Offender Registration Act (KORA), holding that the court of appeals panel erred when it declined to review Defendant's claim challenging her duty to register under the invited error doctrine, but the argument failed on the merits.During trial, Defendant filed a motion arguing that the State would need to prove she had a culpable mental state when she failed to register. The district court denied the motion, concluding that failure to register was a strict liability crime. The court of appeals affirmed, rejecting Defendant's defense of substantial compliance. The Supreme Court affirmed, holding (1) substantial compliance is not an available defense to a charge of failure to register under KORA; (2) the unavailability of a substantial compliance defense did not violate Defendant's due process rights; (3) Defendant had standing to challenge KORA on its face as unconstitutional; and (4) while the court of appeals erred when it held that Defendant could not challenge the sufficiency of the State's evidence because she invited any error, Defendant's claim still failed on the merits. View "State v. Stoll" on Justia Law

The Supreme Court affirmed Defendant's convictions for felony murder, intentional second-degree murder, felony theft of a firearm, felony theft of a vehicle, and burglary, holding that there was no error in the proceedings below.On appeal, Defendant raised three arguments attacking the sufficiency of the State's evidence supporting his convictions. The Supreme Court affirmed, holding (1) the evidence, viewed in a light most favorable to the State was sufficient to support the convictions, and the jury was not required to stack inferences in convicting Defendant; and (2) the district court did not err in denying Defendant's request for a lesser included offense instruction on voluntary manslaughter. View "State v. Colson" on Justia Law