Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's convictions of attempted capital murder, aggravated criminal sodomy, and aggravated burglary, holding that there were no errors in the proceedings below.Specifically, the Supreme Court held (1) the district court did not err in denying Defendant's request for independent DNA testing; (2) the district court did not err in denying Defendant's request for new appointed counsel; (3) the district court did not err in denying Defendant's request for standby counsel; and (4) the State did not violate Defendant's due process rights under Brady by failing to disclose evidence of fingerprint testing. View "State v. Breitenbach" on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendant's motion for postconviction DNA testing, holding that the district court did not err.In 1993, Defendant was convicted of the second-degree murder of his wife. In 2009, Defendant filed a motion seeking postconviction DNA testing pursuant to Kan. Stat. Ann. 21-2512, which authorizes individuals who have been convicted of first-degree murder or rape to petition for such testing. The district court denied the motion because Defendant was convicted of neither offense. The Supreme Court reversed and remanded in Cheeks I, concluding that Defendant's exclusion from section 21-2512 violated his equal protection rights. Meanwhile, the Supreme Court decided State v. LaPointe, 434 P.3d 850 (2019), which overruled Cheeks I. Relying on LaPointe, the district court against denied Defendant's motion for postconviction testing. The Supreme Court affirmed, holding that LaPointe is binding precedent and overrules Cheeks I. View "State v. Cheeks" on Justia Law

The Supreme Court affirmed the adjudication decision of the district court finding F.C. to be a child in need of care (CINC) under Kan. Stat. Ann. 38-2202(d)(2), which focuses on whether the child lacks necessary care or control, and Kan. Stat. Ann. 38-2202(d)(3), which focuses on whether the child has been abused or neglected, holding that the State proved F.C. was a CINC.On appeal, the court of appeals held that there was insufficient evidence that F.C.'s mother or stepfather inflicted emotional harm and that the State failed to establish that F.C. had been emotionally abused under section 38-2202. The Supreme Court reversed, holding (1) section 38-2202(d)(2) limits the trial court's focus only to the present circumstances at the time of the adjudication hearing; and (2) there was clear and convincing evidence to show that F.C. had been subjected to emotional abuse by her stepfather, as that term is defined under subsection (d)(3). View "In re F.C." on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendant's motion to withdraw his guilty plea to first-degree murder, holding that the district court did not abuse its discretion when it found that Defendant failed to establish good cause and denied his motion to withdraw plea.In his motion to withdraw his plea, Defendant argued that his counsel was ineffective for failing to investigate a voluntary intoxication theory of defense because Defendant had told counsel that he was on antidepressants at the time of the murder. The trial court denied the motion, finding counsel's investigation of Defendant's medication legally sufficient to support a finding of competent representation. The Supreme Court affirmed, holding that the district court did not abuse its discretion. View "State v. Barber" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of a panel of the court of appeals vacating Defendant's sentence of seventy-eight months' imprisonment and addressing and determining the three additional issues raised by the parties on appeal, holding that the holding of the panel on two issues was merely advisory.On appeal, Defendant argued that the district court erred in imposing lifetime postrelease supervision and lifetime electronic monitoring and erred in failing to grant him good time credit. For the first time on appeal, the State argued that the district court imposed an illegal sentence by departing more than fifty percent from a standard guideline sentence. The panel concluded that the district court illegally sentenced Defendant to only seventy-eight months and then determined the other issues raised on appeal. The Supreme Court held (1) the panel correctly determined that the seventy-eight-month sentence imposed was illegal; and (2) because any further consideration on the merits could result in holds merely advisory, the panel's holdings on the two remaining issues on review is vacated. View "State v. Dunn" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that no exceptions extended the statutory speedy trial period in this case and that Defendant must be discharged from liability on the charges against him, holding that the State violated Defendant's statutory speedy trial rights.Defendant was charged with premeditated first-degree murder and two counts of attempted first-degree murder. The State did not bring Defendant to trial until 153 days after his arraignment. After he was convicted, Defendant appealed, arguing that the State violated his statutory right to a speedy trial. The Supreme Court agreed and reversed Defendant's convictions, holding that, under Kan. Stat. Ann. 22-3402(a), Defendant's right to a speedy trial was violated. View "State v. Queen" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals vacating Defendant's sentence and remanding the case to the district court for resentencing, holding that the court of appeals panel lacked the requisite authority to reform the plea agreement after finding the sentence imposed was illegal.Defendant entered into a plea agreement with the State in which Defendant agreed to plea no contest to aggravated robbery. The district court imposed a 180-month prison sentence as the State recommended. Defendant appealed his sentence, claiming for the first time on appeal that the district court erred by scoring his two pre-1993 Kansas burglaries convictions as person felonies for purposes of calculating his criminal history score. The panel agreed and sua sponte nullified the sentencing recommendation portion of the plea agreement. The court then held that the parties were free on remand to argue for a correct presumptive sentence. The Supreme Court reversed in part, holding that the court of appeals exceeded the scope of its authority when it reformed the parties' plea agreement as part of its remand order. View "State v. Tonge" on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant's motion for leave to appeal out of time, holding that the district court did not err in denying Appellant's motion under the exceptions set forth in State v. Ortiz, 640 P.2d 1255 (1982).This was the third of Appellant's appeals from the district court's decision denying his motion for leave to appeal out of time. Twice before, the Supreme Court considered Appellant's case and reversed the district court's decision and remanded the matter. In this appeal, Appellant argued that he was entitled to file an untimely appeal under the first and third Ortiz exceptions. The Supreme Court affirmed the district court's ruling denying Appellant's motion, holding that the district court correctly denied Appellant's motion to appeal out of time. View "State v. Smith" on Justia Law

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