Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the district court denying Defendant's postsentence motion to withdraw his pleas of guilty to two counts of premeditated murder, holding that the district court did not abuse its discretion and did not commit reversible error.Pursuant to a plea agreement, Defendant pleaded guilty to two premeditated murder charges for the death of his wife and the unborn child she was carrying. The district court accepted the terms of the agreement and sentenced Defendant to two concurrent hard fifty terms of life imprisonment. Defendant subsequently filed a pro se motion to withdraw his guilty plea, arguing that manifest injustice warranted voiding the plea agreement. The district court denied the motion after a hearing. The Supreme Court affirmed, holding that Defendant did not demonstrate that the district court's findings were arbitrary or unreasonable, were based on an error of law, or were based on an error of fact. View "State v. Cott" on Justia Law

The Supreme Court affirmed the decision of the district court determining that Appellant's claim for attorney fees and expenses should be decided by the court and not a jury, holding that Section 5 of the Kansas Constitution Bill of Rights does not guarantee the right to a jury trial to determine an award of attorney fees and expenses.The two cases leading to the attorney fee dispute arose of the sale of real property to Appellant. The first lawsuit was filed in 2013, and the second lawsuit was filed in 2015. After the case was decided, the district court denied Appellant's request for a jury trial on the issue of attorney fees and expenses, determining that the issue would be heard by the court and not by a jury. The Supreme Court affirmed, holding (1) the Kansas Constitution does not guarantee the right to a jury trial to determine whether attorney fees and expenses should be award; (2) Appellant waived her request for a jury trial to determine attorney fees in the 2013 case; and (3) Appellant's claim for attorney fees under the third-party litigation exception to the American rule is an equitable claim that should be decided by the court rather than a jury. View "Harder v. Estate of Foster " on Justia Law

The Supreme Court affirmed Defendant's convictions of both first-degree premeditated murder and the alternative charge of first-degree felony murder, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the district court did not err in denying Defendant's request for a jury instruction on voluntary intoxication because insufficient evidence supported Defendant's voluntary intoxication defense; (2) the district court did not abuse its discretion in admitting photographs of the victim's body at trial because, while the photographs may have been gruesome, they were relevant and admissible to show the manner and nature of the victim's death and to corroborate certain testimony; and (3) cumulative error did not deny Defendant a fair trial. View "State v. Morris" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and criminal discharge of a firearm, holding that Defendant's claims of trial error and challenge to his sentence were unavailing.Specifically, the Supreme Court held (1) the district court did not err in failing to give Defendant's requested jury instruction on unintentional but reckless second-degree murder as a lesser included offense of first-degree premeditated murder; (2) the district court did not err by allowing the State to introduce two out-of-court statements; (3) the district court did not err in allowing into evidence eight autopsy photos, a video, and two photos investigators took of Defendant at the time of questioning; and (4) the district court did not abuse its discretion in denying Defendant's motion for a departure sentence. View "State v. Randle" on Justia Law

The Supreme Court affirmed Defendant's convictions of first-degree felony murder, aggravated robbery, conspiracy to commit aggravated robbery, criminal possession of a firearm, fleeing and eluding, and interference with law enforcement, holding that Defendant's arguments on appeal failed.Specifically, the Supreme Court held (1) any possible violation of Defendant's Fifth Amendment right in the admission of a witness's testimony about Defendant giving the witness phone passcodes was undoubtedly harmless; (2) the district court did not err by admitting hearsay statements as statements of a coconspirator and contemporaneous statements; (3) the State introduced sufficient evidence to convict Defendant of first-degree murder; and (4) the district judge did not abuse its discretion by admitting testimony that Defendant was upset over a meth pipe that went missing. View "State v. Lemmie" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for first-degree felony murder, holding that there was no error in the proceedings below.A jury found Defendant guilty of both first-degree felony murder and second-degree intentional murder. At sentencing, Defendant moved for a new trial and judgment notwithstanding the verdict, arguing that the jury must have had reasonable doubt on the first-degree felony murder theory because it convicted him of second-degree murder for the same killing. The district court dismissed the second-degree murder conviction and sentenced Defendant for the felony murder over his objection. The Supreme Court affirmed, holding (1) the district court did not err when it sentenced Defendant on felony murder instead of declaring a mistrial because Defendant did not establish that the jury failed to find each element of the felony murder beyond a reasonable doubt or that the jury's first- and second-degree murder verdicts were so irreconcilable as to require a new trial; and (2) the district court did not err in declining to give an instruction on voluntary intoxication. View "State v. Craig" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's challenge to the constitutionality of his sentence, holding that because Defendant did not object to the district court's failure to make factual findings at sentencing and he did not file a motion under Kansas Supreme Court Rule 165, Defendant's as-applied challenge to the constitutionality of his sentence was not amenable to appellate review.Defendant pleaded guilty to first-degree felony murder, an off-grid person felony mandating a hard twenty-five sentence. Before sentencing, Defendant argued that his hard twenty-five sentence was unconstitutional as applied to the facts of his case under section 9 of the Kansas Constitution Bill of Rights. The district court found the sentence constitutional. The Supreme Court affirmed, holding that because Defendant failed to meet his obligation to ensure the district court made the factual findings necessary for appellate review, Defendant failed to preserve his as-applied constitutional challenge for appellate review. View "State v. Espinoza" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court dismissing the second-degree murder and aggravated battery charges against Defendant on the grounds that Defendant had reasonable grounds to believe he was in danger of great bodily harm, holding that Defendant was not entitled to immunity from prosecution under Kan. Stat. Ann. 21-5231.A court of appeals panel reversed the decision of the district court concluding that Defendant was entitled to statutory self-defense immunity, holding that the facts as found by the district court did not support a grant of immunity. The Supreme Court affirmed, holding that, on the facts as found by the district court, there was probable cause to believe Defendant's use of force was not statutorily justified. View "State v. Collins" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the decision of the district court granting Defendant's pretrial motion to dismiss his charge of first-degree murder based on self-defense immunity, holding that the district court failed to make adequate findings of fact and conclusions of law on the record.The State charged Defendant with first-degree premeditated murder. Defendant moved to dismiss based on self-defense immunity. After a hearing, the district court dismissed the complaint, holding that the State did not meet its burden to show probable cause that self-defense immunity did not apply. The district court made no distinct factual findings. The court of appeals panel reversed and remanded for a rehearing. The Supreme Court affirmed, holding that under the circumstances of this case, the court of appeals' ruling was appropriate. View "State v. Thomas" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree premeditated murder, holding that the district court did not err in its challenged instructions to the jury.Specifically, the Supreme Court held (1) the district court did not err in refusing to give the jury Defendant's requested instruction on voluntary manslaughter as a lesser included offense of first-degree murder because the instruction was not factually appropriate; and (2) the district court did not commit clear error in issuing an unmodified version of Instruction No. 11, which contained the definition of "premeditation" and mirrored PIK Crim. 4th 54.150(d) because the instruction was legally appropriate. View "State v. Uk" on Justia Law