Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction and sentence for one count of aggravated indecent liberties with a child, holding that no error occurred in the conduct of Defendant's trial that required reversal.The State charged Defendant with one count of aggravated indecent liberties with a child who was fourteen or more years of age but less than sixteen years of age. The State filed a motion seeking admission of evidence under Kan. Stat. Ann. 60-455(d) that Defendant had been convicted of two sex crimes in Missouri. The court granted the motion, finding that the evidence was material and had probative value. The jury found Defendant guilty. The court of appeals affirmed. Defendant appealed, arguing that the district court abused its discretion by allowing the State to introduce the fact of his prior Missouri convictions for sex crimes. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting the evidence; (2) section 60-455(d) does not violate the Bill of Rights contained in the Kansas Constitution; and (3) the record did not support Defendant's speedy trial claims. View "State v. Razzaq" on Justia Law

In this appeal concerning the statutory definition of "idiopathic causes" contained in the statute excluding benefits for certain accidents or injuries the Supreme Court held that the Workers Compensation Appeals Board improperly denied benefits to Terrill Graber, who was injured when he fell down a workplace stairway, holding that there was not substantial competent evidence to support the Board's finding that the accident or injury arose directly or indirectly from an idiopathic cause under the statutory exclusion.There was no evidence presented in this case showing why Graber fell down the workplace stairway. The Board construed the term "idiopathic causes" in Kan. Stat. Ann. 44-508(f)(3)(A)(iv) broadly to cover all unknown causes and denied compensation. The court of appeals reversed after defining the term more narrowly. The Supreme Court affirmed and remanded the case to the Board for reconsideration consistent with this opinion, holding that the term "idiopathic causes" in this context means medical conditions or medical events of unknown origin that are peculiar to the injured individual. View "Estate of Graber v. Dillon Companies" on Justia Law

In this Kansas Sexually Violent Predator Act (KSVPA) case, Kan. Stat. Ann. 59-29a01 et seq., the Supreme Court remanded Thomas Easterberg's action seeking a petition for writ of habeas corpus, holding that there was a fact question for the district court to resolve in order to determine whether Easterberg's writ should be granted.Easterberg pled guilty to kidnapping and aggravated battery. On the sentencing guidelines journal entry of judgment for these convictions, the district court indicated that Easterberg's crimes were not sexually motivated for purposes of the Kansas Offender Registration Act, Kan. Stat. Ann. 22-4902(c)(14). Thereafter, the Attorney General's Office filed a petition seeking to involuntarily commit Easterberg as a sexually violent predator. Easterberg moved to dismiss the action, arguing that the State had no statutory basis to file the petition for his commitment. The district court denied the motion to dismiss. Easterberg then filed this original action. The Supreme Court remanded this case to the district court for a determination of whether the issue of sexual motivation was litigated in Easterberg's criminal case. If so, the State would be estopped from relegating that point in the KSVPA proceeding and Easterberg would not be eligible for involuntary commitment. If not, the KSVPA proceeding would continue. View "In re Care & Treatment of Easterberg" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion for a new trial based on newly discovered evidence, holding that the district court correctly held that the motion was untimely filed.Defendant filed his motion under Kan. Stat. Ann. 22-3501, arguing that newly discovered evidence justified a new trial. The district court denied the motion, concluding that, under section 22-3501(1), the motion was out-of-time. On appeal, Defendant argued that the district court erred in holding that the two-year period in which the motion for a new trial must be filed began from the date the Supreme Court mandate was issued. Rather, Defendant argued that the final judgment was when the district conducted a "remand hearing." The Supreme Court disagreed, holding that the mandate was fully determinative of the issues and therefore rendered the judgment final. View "State v. Phillips" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentences, holding that the district court did not err.Defendant was convicted of one count of first-degree premeditated murder and one count of arson. The Supreme Court upheld Defendant's convictions but remanded the case for resentencing of Defendant's hard fifty life sentence. After a resentencing hearing, the court sentenced Defendant to a hard twenty-five life sentence. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant's motion to dismiss at the resentencing hearing; (2) Defendant was barred from raising ineffective assistance of trial and appellate counsel claims for the first time on appeal; (3) the district court did not err in denying Defendant's request for exculpatory evidence; and (4) the district court did not engage in judicial misconduct in denying Defendant's right to allocution. View "State v. Salary" on Justia Law

In this employment case arising out of the sale of a cattle feedlot the Supreme Court affirmed the decision of the court of appeals reversing summary judgment on Plaintiff's implied-in-fact employment contract claim and Plaintiff's claim for promissory estoppel, holding that a genuine issue of material fact existed preventing summary judgment.Plaintiff moved his employment from the old owner of the feedlot to the new owner, Defendant. Because of operational changes, Defendant later terminated Plaintiff's employment. Plaintiff then sued Defendant alleging breach of an employment contract, or in the alternative, detrimental reliance and estoppel. The district court concluded that Plaintiff was Defendant's employee at will, and therefore, Defendant could terminate Plaintiff's employment at any time without cause. The court of appeals reversed, holding that whether Plaintiff's employment was at will - or protected by an implied-in-fact contract - was a disputed question of fact. The Supreme Court affirmed, holding (1) whether a meeting of minds existed between the parties on an implied-in-fact employment contract presented a genuine issue of material fact precluding summary judgment; and (2) therefore, summary judgment should not have been granted for Defendant on Plaintiff's promissory estoppel claim. View "Peters v. Deseret Cattle Feeders, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals vacating the jury verdict in favor of Charles Dawson as to his claim that the negligence of his employer, BNSF Railway Company, caused his back injuries, holding that reasonable minds could reach different conclusions as to whether Dawson’s claim was timely.In 1979, Dawson began his employment with BNSF as a switchman and brakeman and later worked as a conductor. In 2008, Dawson began experiencing back pain. In 2011, Dawson filed this action against BNSF under the Federal Employers’ Liability Act (FELA) alleging that BNSF’s negligence led to his injuries. The jury returned a verdict in favor of Dawson. The court of appeals reversed, concluding that the district court erred when it denied BNSF’s motion for judgment as a matter of law because Dawson’s cumulative claim was time barred and that Dawson’s acute injury claims were time barred. The Supreme Court reversed the court of appeals and affirmed the district court, holding that the district court did not err when it submitted the statute of limitations question to the jury. View "Dawson v. BNSF Railway Co." on Justia Law

The Supreme Court affirmed the summary denial of Appellant’s motion to correct illegal sentence, holding that Appellant’s motion to correct illegal sentence was without merit.Appellant was sentenced to a hard twenty-five life sentence after pleading no contest to rape of a child under the age of fourteen. Several years later, Appellant filed a pro se motion to correct illegal sentence. The district court judge dismissed the motion without holding a hearing. On appeal, Appellant conceded that summary denial of his motion was appropriate but that he was nevertheless entitled to relief. For the first time, Appellant argued that the handling of his pre-plea competency issue deprived the district court of jurisdiction to sentence him. The Supreme Court affirmed, holding that a motion to correct illegal sentence was an improper vehicle for Appellant’s new challenge. View "State v. Roberts" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree murder and aggravated assault for stabbing her ten-year-old son to death while suffering from a psychotic episode, holding that there was one instance of prosecutorial error in this case, but it was harmless.On appeal, Defendant challenged the jury instructions concerning her mental disease or defect disease, alleged several instances of prosecutorial error, and claimed that cumulative error warranted reversal of her convictions. The Supreme Court affirmed, holding (1) Defendant failed to establish instructional error because the instructions did not prevent the jury from considering how Defendant’s mental disease or defect otherwise affected her ability to premeditate; (2) the single instance of prosecutorial error was harmless; and (3) the single error in this case was insufficient to support reversal under the cumulative effect rule. View "State v. Blansett" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant’s convictions, holding that the district court did not clearly err by failing to instruct on voluntary intoxication in determining Defendant’s guilt on charges of criminal trespass and interference with law enforcement.On appeal, the court of appeals concluded that a voluntary intoxication instruction was not legally appropriate for the criminal trespass and interference with law enforcement charges. The Supreme Court affirmed but on different grounds, holding (1) it was error for the judge not to instruct on voluntary intoxication as a potential defense with respect to both crimes; but (2) the judge’s error in failing to give the voluntary intoxication instruction did not rise to clear error. View "State v. Murrin" on Justia Law