Justia Kansas Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to suppress evidence on the ground that incriminating evidence was obtained as the result of an unlawful seizure, holding that officers unlawfully detained Defendant and conducted an illegal search.Defendant was seated in a car lawfully parked in an apartment complex parking lot when two officers approached the car. Defendant's hands were clenched and held in front of him, and one officer commanded Defendant to open his hand. Defendant opened his hand and dropped a small bag of cocaine. Defendant moved to suppress the evidence, but the district court denied the motion, finding that the encounter was voluntary. The court of appeals affirmed. The Supreme Court reversed and remanded for further proceedings, holding that the detention was unlawful because the officer lacked reasonable suspicion of criminal activity to detain Defendant, and therefore, the evidence obtained as a result must be suppressed because it was tainted by an unlawful seizure. View "State v. Andrade-Reyes" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that Defendant's sentence, which was legal when it was imposed, was not illegal due to subsequent changes in the law.Defendant pleaded guilty to one count of attempted rape. At sentencing, the district court determined that Defendant had a criminal history score of B in part due to a prior California robbery conviction, which the Kansas court classified as a person felony. Defendant later filed a motion to correct an illegal sentence, arguing that the district court incorrectly calculated his criminal history score by classifying his California conviction as a person felony contrary to recent changes in the law. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding that where Defendant's sentence was legal when it was pronounced, it was not illegal because the law subsequently changed. View "State v. Newton" on Justia Law

The Supreme Court affirmed Defendant's convictions of first-degree murder under theories of premeditation and felony murder, attempted first-degree murder, and other offenses, holding that the district court did not err in the proceedings below.Specifically, the Court held (1) the district court did not err in concluding that Defendant was not entitled to a change of venue under Kan. Stat. Ann. 22-2616; and (2) the district court did not violate Defendant's Fifth Amendment rights when it denied Defendant's motion to suppress his confession because Defendant knowingly and intelligently waived his previously invoked right to counsel and because the confession was voluntary. View "State v. Palacio" on Justia Law

The Supreme Court affirmed the decision of the court of appeals that Alice King was the legal owner of minerals under a section of land that was the subject of this lawsuit (the Property) and that Luther Term Interest Holders could not establish the elements of adverse possession in this case.In 2009, Oxy USA, Inc. developed an oil and gas well on a unitized production unit of land that included the Property. While the well was not located on the Property, the owner of the minerals under the Property was entitled to receive royalties from the production. Oxy initiated this interpleader and quiet title action to determine the rightful legal owner of the minerals under the property. King owned the surface of the property and an undisputed one-half interest in the minerals. Luther Term Interest Holders, dozens of people and entities, claimed some fraction of the disputed one-half mineral interest. The district court granted summary judgment in favor of the Luther Term Interest Holders. The court of appeals reversed. The Supreme Court affirmed, holding that title in the disputed minerals must be quieted in favor of King. View "Oxy USA, Inc. v. Red Wing Oil" on Justia Law

The Supreme Court reversed the decision of the court of appeals ruling that the district court's error in denying Defendant's request for an instruction on imperfect self-defense voluntary manslaughter was harmless, holding that the error was reversible because there was a reasonable probability that it affected the trial's outcome.Defendant, who had schizophrenia, killed a man who entered his apartment to exterminate bugs because he felt irrationally threatened by the victim. At issue during trial was whether Defendant's mental condition precluded him from forming a culpable mental state. The jury found Defendant guilty of reckless second-degree murder. The court of appeals affirmed, holding that the district court erred when it failed to give a voluntary manslaughter instruction - an intentional killing done with the unreasonable but honest belief that circumstances existed justifying the deadly force - but that the instructional error was harmless under the so-called "skip rule." The Supreme Court reversed and remanded for a new trial, holding that the trial court's error in failing to give an imperfect self-defense voluntary manslaughter instruction was reversible because the jury could have reasonably convicted Defendant of voluntary manslaughter. View "State v. Barrett" on Justia Law

The Supreme Court held that through Senate Bill 16's (S.B. 16) additional funding of the State's "Montoy safe harbor plan," the State substantially complied with this Court's mandate from Gannon v. State, 420 P.3d 477 (Kan. 2018) (Gannon VI).In Gannon VI, the Supreme Court held that the State had resolved nearly all of the issues in this school finance appeal but that the State had not met Kan. Const. Art. 6, 6(b)'s adequacy requirement. The Supreme Court retained jurisdiction and stayed the issuance of its mandate in order to give the State ample opportunity to make the necessary financial adjustments and reach constitutional compliance. The State subsequently passed S.B. 16, which the Governor signed into law on April 6, 2019. The Supreme Court held that the State substantially complied with the Court's Gannon VI mandate through S.B. 16's financial adjustments to the safe harbor plan. The Court retained jurisdiction to ensure continued implementation of the scheduled funding. View "Gannon v. State" on Justia Law

The Supreme Court affirmed the district court's denial of Defendant's motion to correct an illegal sentence, holding that the sentencing court properly classified Defendant's 1976 Michigan conviction as a person crime in accordance with State v. Murdock, 439 P.3d 307 (Kan. 2019).Defendant pleaded guilty to a 2007 attempted robbery. A presentence investigation (PSI) revealed that Defendant had two prior convictions - a 1976 Michigan conviction for assault with intent to commit criminal sexual conduct and a 1979 Michigan conviction for criminal sexual conduct. The previous convictions were scored as person felonies, giving Defendant a criminal history score of B. In 2014, Defendant filed his motion to correct an illegal sentence, arguing that both Michigan convictions should have been scored as nonperson felonies based on recent changes in law. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed in accordance with Murdock, which holds that a sentence that was legal when pronounced does not become illegal if the law subsequently changes. View "State v. Weber" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court reversing the suspension of Appellant's driving privileges based on her arrest and refusal to take a blood alcohol test, holding that substantial competent evidence supported the district court's factual findings and that the court's legal conclusions were correct.The district judge held that Appellant met her burden of proving both that the arresting officer lacked reasonable grounds to believe that Appellant was driving while impaired and lacked probable cause to arrest her. In reversing, the court of appeals ruled that the totality of the circumstances did not support Appellant's position. The Supreme Court reversed, holding that substantial competent evidence in the record supported the district court's factual findings and that the conclusion derived from those findings was legally correct. View "Casper v. Kansas Department of Revenue" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court, holding that the noneconomic damages cap under Kan. Stat. Ann. 60-19a02 violated Plaintiff's right under section 5 of the Kansas Constitution Bill of Rights because it intrudes upon the jury's determination of the compensation owed her to redress her injury.In this auto-truck accident case, Plaintiff received a jury award of $335,000. The district court applied section 60-19a02 to reduce Plaintiff's jury award to a judgment of $283,490.86. The district court acknowledged that Plaintiff's case was distinguishable from Miller v. Johnson, 289 P.3d 1098 (Kan. 2012), in which a majority of the Court upheld the application of the noneconomic damages cap to a medical malpractice plaintiff's jury award, but ultimately ruled that section 60-19a02 was constitutional. The court of appeals affirmed. The Supreme Court reversed and remanded for entry of judgment in Plaintiff's favor on the jury's full award, holding that the cap on damages imposed by section 60-19a02 is facially unconstitutional because it violates section 5 of the Kansas Constitution Bill of Rights. View "Hilburn v. Enerpipe Ltd." on Justia Law

The Supreme Court affirmed the court of appeals majority's decisions to reverse the district judge's decision to suppress evidence and appropriate instructions for her further action on remand but altered the court's instructions to match those suggested in the dissent, holding that when a district judge's legal ruling in favor of the defense on a motion to suppress is infected with an obviously incorrect assessment of the State's evidence that is equivalent to an arbitrary disregard of a portion of the evidence, the district judge should have another change to review the record and explain himself or herself.Defendant was charged with drug related offenses. Defendant filed a motion to suppress the evidence, which the district court granted. A majority of the reviewing court of appeals panel reversed and remanded with instructions to deny the motion to suppress. Dissenting Judge Thomas E. Malone concurred in the reversal and remand but argued that the district judge should be permitted to reconsider the motion with a corrected understanding of the evidence before her. The Supreme Court affirmed, holding that the district judge should not be directed to deny Defendant's motion but to reconsider it in light of a corrected understanding of the evidence before her. View "State v. Douglas" on Justia Law