Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals reversing Defendant’s conviction for aggravated criminal sodomy, holding that the conviction was unsupported by sufficient evidence of the crime the State charged.Defendant was found guilty by a jury of aggravated criminal sodomy, and the district court gave Defendant a life sentence. On appeal, Defendant challenged the charging document, which charged Defendant with causing the complainant “to engage in oral copulation with another person” under Kan. Stat. Ann. 21-5504(b)(2). The court of appeals reversed, relying on State v. Laborde, 360 P.3d 1080 (Kan. 2015), and State v. Dickson, 69 P.3d 549 (Kan. 2003). The State filed a petition for review, arguing that Dickson was wrongly decided and applied and that any error in the charging document was not reversible because it informed Defendant of the accusation he must defend against. The Supreme Court disagreed, holding (1) the State’s invitation to overrule Dickson is declined; and (2) the State did not present sufficient evidence of the crime of aggravated sodomy as charged under section 21-5504(b)(2). View "State v. Fitzgerald" on Justia Law

The Supreme Court affirmed the order of the district court committing Defendant to Larned State Hospital for care and treatment after finding that he was mentally ill and dangerous under Kan. Stat. Ann. 59-2946(e) and (f)(3), holding that Snyder’s constitutional rights were not violated and that the evidence was sufficient to involuntarily commit him.The district court found by clear and convincing evidence that Snyder was a mentally ill person subject to involuntary commitment for care and treatment. The Supreme Court affirmed, holding (1) Snyder was not denied equal protection; (2) Snyder was not denied due process; and (3) the State presented sufficient evidence that Snyder was likely to cause harm to others. View "In re Care & Treatment of Snyder" on Justia Law

The Supreme Court held that although the Prairie Village Police Department (PVPD) violated Kan. Stat. Ann. 22-2401a(2) when it conducted two controlled buys from J.O., a juvenile, at her residence, the district court did not err when it decided not to suppress the evidence.On appeal, J.O. argued that the district court should have suppressed the evidence because it had found that the PVPD willfully and repeatedly violated section 22-2401a, which generally authorizes city law enforcement officers to act within the city’s limits or on property under the control of the city. The Supreme Court disagreed, holding that the district court properly denied J.O.’s motion to suppress because (1) the district court took other action to deter future violations of the statute; (2) J.O. did not allege a constitutional violation or otherwise state a cognizable injury to her substantial rights; and (3) section 22-2401a did not vest J.O. with an individual right. View "In re J.O." on Justia Law

The Supreme Court denied Clay Robert Snyder’s petition for habeas relief in which he requested release from his confinement and dismissal of his criminal charges with prejudice, holding that there were no federal speedy trial, due process, or equal protection violations warranting habeas relief.In 2012, Snyder was charged with rape and other offenses. The district court granted defense counsel’s motion to determine Snyder’s competency to stand trial and subsequently found Snyder not competent to stand trial because of his intellectual disability. Afterwards, Snyder went through competency detainment and involuntary commitment at least twice. In 2016, the district court found that Snyder was still not competent to stand trial and ordered the State to initiate civil commitment proceedings against him. Snyder then brought this habeas proceeding. The Supreme Court denied Snyder’s petition for habeas relief, holding (1) Snyder was not denied a speedy trial; (2) Snyder was not denied due process; and (3) Snyder’s equal protection claim was abandoned. View "In re Petition for Writ Habeas Corpus by Snyder" on Justia Law

The Supreme Court held that a law enforcement officer lacked an articulable and reasonable suspicion that the unidentified driver of a car stopped at a traffic stop did not have a valid driver’s license, and therefore, the district court properly granted Defendant’s motion to suppress evidence obtained during the stop.The officer in this case stopped the car because he assumed the driver was the registered owner, whose driver’s license had been revoked. Defendant, the driver, filed a motion to suppress, arguing that the officer lacked a reasonable suspicion of illegal activity when he stopped the car. The district court denied the motion. The court of appeals reversed, holding that reasonable suspicion can arise because an officer may presume the owner is the driver absent contrary information. The Supreme Court reversed, holding that the court of appeals’ owner-is-the-driver presumption is invalid because it implicitly requires applying and stacking unstated assumptions that are unreasonable without further factual basis and relieves the State of its burden of proving that the officer had particular and individualized suspicion that the registered owner was driving the vehicle. View "State v. Glover" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant’s convictions for possession of marijuana with intent to sell and failure to pay the Kansas drug tax stamp, holding that there was reasonable suspicion to support the seizure of an intercepted UPS package.Defendant filed a motion to suppress the evidence resulting from the detention of the intercepted UPS package, arguing that law enforcement seized the package in violation of his constitutional rights because reasonable suspicion was lacking where there was nothing unusual about the package’s appearance. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the government had reasonable suspicion to seize the package; and (2) the court of appeals did not err when it held that Defendant had not preserved his argument that the authorities detained his package for an unreasonable length of time. View "State v. Ton" on Justia Law

The Supreme Court held that summary judgment was improperly granted to a title company on negligence and breach of fiduciary duty claims that arose out of the company’s omission of a reserved mineral interest in a deed and its handling of a later conveyance.In granting summary judgment, the district court determined that the relevant statute of limitations barred the claims. A court of appeals panel reversed. The Supreme Court affirmed, holding (1) as to the negligence claim, a genuine issue of material fact existed as to when the cause of action accrued, and the case must therefore be remanded for further proceedings; and (2) the breach of fiduciary duty claim was not excusable from further litigation because of the statute of limitations, as the claim was brought well within the allowable period. View "LCL, LLC v. Falen" on Justia Law

The Supreme Court affirmed Defendant’s convictions for first-degree murder, two counts of aggravated burglary, and other crimes, holding that none of Defendant’s contentions on appeal warranted reversal.Specifically, the Supreme Court held (1) there was sufficient evidence to support Defendant’s convictions for aggravated burglary, first-degree murder, and theft; (2) the district court did not abuse its discretion when it found that no juror misconduct occurred; and (3) the district court did not abuse its discretion when it found that it could retrospectively determine whether Defendant was competent to stand trial. View "State v. Jenkins" on Justia Law

Defendant had a reasonable expectation of privacy in Alexis Tracy’s apartment at the time the apartment was searched by law enforcement officers, and therefore, Defendant had standing to challenge the search.Law enforcement officers failed to find Defendant in a search of Tracy’s apartment but did find Defendant’s safe, which contained methamphetamine. The State charged Defendant with possession with intent to distribute methamphetamine and no drug tax stamp. Defendant moved to suppress the evidence, arguing that the search exceeded the scope of Tracy’s consent. The district court suppressed the evidence. The court of appeals reversed, concluding that Defendant lacked standing to challenge the search because he was not present at the time of the search and therefore was not a current guest at Tracy’s apartment. The Supreme Court remanded to the court of appeals for further proceedings, holding that Defendant was a welcomed social guest at Tracy’s apartment and did not lose any reasonable expectation of privacy the moment he left the apartment. View "State v. Dannebohm" on Justia Law

In this case involving the manifest justice factors in Kan. Stat. Ann. 60-1507, both pre- and post-amendment, the Supreme Court held that, based on the record before it, it could not be determined whether Defendant established manifest injustice.On year after a statutory deadline, Defendant filed a section 60-1507 motion asking the district court to apply the manifest injustice exception in section 60-1507(f), which allows consideration of section 60-1507 motions even if filed late. The district court denied the motion. While Defendant’s appeal was pending, the Legislature amended the statute and changed the manifest injustice factors. The Supreme Court remanded the case, holding (1) the amendments to section 60-1507 do not apply retroactively, and the preamendment factors govern Defendant’s appeal; and (2) although the district court applied the preamendment factors, the court’s findings of fact are insufficient for appellate review. View "White v. State" on Justia Law