Justia Kansas Supreme Court Opinion Summaries

The Supreme Court reversed the decision of a panel of the court of appeals vacating Defendant's conviction for aggravated kidnapping, thus reaffirming that the three-part test fashioned in State v. Buggs, 547 P.2d 720 (Kan. 1976), to ensure that a defendant is not convicted of two crimes for identical conduct when a person confines someone with the intent to facilitate the commission of another crime, did not apply to circumstances such as those presented in this case.Under the Buggs test, a kidnapping conviction cannot stand if the confinement was "incidental to" or "inherent in the nature of" the other crime or if the confinement did not make commission of the other crime "substantially easier." The court of appeals concluded that the test applied to kidnappings, like Defendant's, committed with the intent to inflict bodily harm to terrorize a person. The court of appeals panel concluded that, under the Buggs test, insufficient evidence supported Defendant's aggravated kidnapping conviction. The Supreme Court reversed, holding that the Buggs test did not apply to this case, where Defendant had confined the victim with the intent to inflict bodily harm or terrorize her. View "State v. Butler" on Justia Law

The Supreme Court reversed Defendant's conviction for aggravated kidnapping and vacated his sentence for that conviction but affirmed the remainder of his convictions, holding that the State did not present sufficient evidence to sustain Defendant's aggravated kidnapping conviction.Defendant appealed his convictions to the court of appeals, which affirmed the trial court's judgment. The Supreme Court reversed in part, holding (1) Defendant's disruptive pretrial behavior provided a lawful basis for the district court to deny Defendant's request to represent himself at trial; (2) Defendant's aggravated kidnapping conviction was supported by insufficient evidence; (3) the jury instructions on the lesser-included offenses of aggravated battery were not factually appropriate, but the instructional error did not warrant reversal of Defendant's aggravated battery conviction; and (4) the cumulative effect of the trial errors did not require reversal. View "State v. Couch" on Justia Law

The Supreme Court overruled the holding in State v. Watson, 885 P.2d 1226 (1994) that the State can convict a defendant for attempted aggravated burglary without proving the defendant intended to enter an occupied dwelling, concluding that this holding is contrary to Kan. Stat. Ann. 21-5301(a).On appeal from his conviction, Defendant argued that Watson's holding was contrary to section 21-5301(a), which imposes a specific intent requirement for all elements of the crime of attempted burglary. The Supreme Court agreed and overruled Watson's holding but, at the same time, affirmed Defendant's conviction for attempted aggravated burglary, holding that the State presented sufficient evidence that Defendant intended to enter a dwelling that was occupied at the time he committed an overt act. View "State v. Larsen" on Justia Law

The Supreme Court answered two certified questions regarding the interplay between an arbitrated award against one set of tortfeasors and a litigated proceeding against another set of tortfeasors in this case concerning Kansas's one-action rule.Timothy Hunt, a farm employee, was killed when operating a grain vacuum to remove corn from a grain trailer. Plaintiff, Hunt's daughter, filed suit in Kansas federal district court against the manufacturer of the grain vacuum system. In the meantime, Hunt's children, including Plaintiff, entered into an arbitration agreement with the farm. An arbitrator entered an award in favor of the claimants. The circuit court entered final judgment confirming the arbitration award. The defendants in the federal court action subsequently moved for summary judgment, arguing that the suit was barred by the one-action rule. The federal court then certified questions to the Supreme Court. The Supreme Court answered (1) an arbitration action does not qualify as a judicial determination of comparative fault where no other potential tortfeasors were involved in the arbitration; and (2) the confirmation of an arbitration award by a state court judgment does not qualify as a judicial determination of comparative fault so as to invite application of the Kansas one-action rule. View "Hodges v. Walinga USA Inc." on Justia Law

The Supreme Court affirmed the order of the district court reversing its order suppressing evidence found in the car that Defendant was driving on two separate occasions where law enforcement discovered drugs and other contraband, holding that the district court did not abuse its discretion in reversing its suppression order but erred in admitting prior drug use.Defendant was convicted by a jury of two counts of possessing methamphetamine and four counts of possessing drug paraphernalia with intent to use to distribute. The court of appeals reversed and remanded for a new trial on the ground that the district court erroneously allowed the State to introduce evidence relating to Defendant's prior convictions for similar crimes. The Supreme Court affirmed, holding (1) the district court erred in admitting prior drug crime evidence, and the error was not harmless; and (2) the district court did not abuse its discretion in granting the State's motion to reconsider its erroneous suppression ruling. View "State v. Campbell" on Justia Law

The Supreme Court reversed the decision of a panel of the court of appeals reversing the district court's determination that a prescriptive easement existed over land owned by the Galls, holding that the panel erred in finding that the Pyles' use was not exclusive because the Pyles did not exclude all others from the asserted easement.The Pyles filed petition seeking to quiet title to a disputed boundary land in this case. The district court found that the Pyles acquired the land by adverse possession and acquired a prescriptive easement across the northern sixty feet of the Galls' land. The court of appeals affirmed the court's adverse possession findings but reversed the finding of a prescriptive easement, concluding that the evidence did not show that the Pyles exclusively used the northern boundary of the Galls' land. The Supreme Court reversed as to the issue subject to review, holding that the element of exclusivity was established in this case in the context of a prescriptive easement. View "Pyle v. Gall" on Justia Law

The Supreme Court affirmed the judgment of the district court granting an uncontested petition of the trustees of the Marvin S. Robinson Charitable Trust to retroactively modify the trust's terms to maintain its tax-exempt status as a "supporting organization" under the federal tax code, holding that Kan. Stat. Ann. 58a-416 authorized the retroactive modification of the trust.Under In Commissioner v. Estate of Bosch, 387 U.S. 456 (1967), which held that the Internal Revenue Service (IRS) and federal courts are not bound by decisions of lower state courts on issues of state law but that these entities will defer to decisions of a state's highest court, an order allowing the retroactive modification of a trust's terms to maintain its tax-exempt status is binding on federal tax authorities only if it emanates from the Supreme Court. The Supreme Court agreed to review the district court's order in accordance with Bosch and affirmed the district court's judgment granting the petition, holding modification of the trust was proper. View "In re Marvin S. Robinson Charitable Trust" on Justia Law

The Supreme Court affirmed the judgment the district court ruling against Defendant on his "Motion to Void Restitution, Reimbursements for Indigent Defense Services and Court Cost and Fees and Witness Fees" based on the law-of-the-case doctrine, holding that there was no error.Defendant, who was serving a life sentence for felony murder, challenged the district court's order of restitution in the amount of $37,521. The court concluded that the State had wrongly been collecting restitution from Defendant's prison account based on a clerical error and ordered it corrected. Defendant further requested that he be refunded $3,347 already improperly collected from his account. The court denied the motion, and the court of appeals affirmed. While his appeal was pending, Defendant filed the motion at issue, repeating an earlier argument that the restitution order was dormant and therefore void. The district court denied the motion, citing the law-of-the-case doctrine. The Supreme Court affirmed, holding that the district court did not err in ruling against Defendant based on the law-of-the-case doctrine. View "State v. Bailey" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals panel reversing the ruling of the district court denying Lisa Webster's request to clarify an order made during her divorce proceedings that she receive a share of Jon's Army Reserve and National Guard retirement pay based on the months of their marriage, holding that the relief from judgment statute, Kan. Stat. Ann. 60-260, was not applicable.When Jon retired about fifteen laters following the parties' divorce Lisa submitted the court's division order to the federal office administering Jon's retirement benefits, but the office told Lisa that it needed more detail to calculate Lisa's share. Lisa filed a motion seeking clarification of the order, which the district court denied. The court of appeals reversed, concluding that the division order was not a final judgment subject to the dormancy statute. The Supreme Court affirmed on different grounds, holding (1) the division order was a final judgment subject to the dormancy statute; and (2) section 60-260 was not applicable because Lisa's request for clarification did not require substantive change to the original property division. View "In re Marriage of Shafer" on Justia Law

In this action involving a district court's division of Jon Holliday's retirement account in a divorce proceeding with Tamara Holliday the Supreme Court held that Kan. Stat. Ann. 60-2403(c)'s tolling provision prevents a divorce decree dividing the parties' interests in a retirement account with the Kansas Public Employees Retirement System (KPERS) from becoming dormant until benefits become payable to the plan member.In 2009, Jon and Tamara divorced. The district court divided Jon's not-year-payable retirement account with KPERS equally between them and directed Tamara to prepare a qualified domestic relations order to "effectuate" the division. In 2021, Jon brought this action claiming that Tamara's judgment from the divorce had gone dormant because she had not sent a copy of it to KPERS as instructed and requesting that the court extinguish Tamara's interest in the account. The district court denied relief, but the court of appeals reversed. The Supreme Court reversed, holding that Kan. Stat. Ann. 60-2403(c) tolled the dormancy period until Jon's benefits from his KPERS account became payable. View "In re Marriage of Holliday" on Justia Law