Justia Kansas Supreme Court Opinion Summaries

The district court properly suppressed drug-related evidence discovered in a vehicle search following a traffic stop because the officer improperly prolonged the traffic stop.The district court found the initial traffic stop was lawful and that the stop ended when the officer gave Defendant a warning citation and his documents and told him he was free to leave. The court concluded that a consensual encounter then occurred but ended when the officer told Defendant to sit down inside the police car and that there was no probable cause to justify the vehicle search. The Supreme Court affirmed, holding that the officer did not have reasonable suspicion to detain Defendant after the traffic stop, and therefore, the State did not meet its burden to show that the challenged seizure was lawful. View "State v. Lowery" on Justia Law

The Supreme Court held that the lower courts erred in concluding that the traffic stop in this case was impermissibly extended.The district court suppressed from evidence thirty-eight pounds of marijuana seized after a traffic stop, finding that the stop was unconstitutionally extended. The court of appeals affirmed. The Supreme Court disagreed with the lower courts, holding (1) discrepancies between the driver’s statements and the vehicle-related documents justified the deputy’s progressive questioning; (2) the questioning occurred simultaneously with the deputy’s appropriate steps in processing the traffic stop; and (3) the circumstances provided the officer reasonable suspicion to extend the detention and for a drug dog sniff. View "State v. Schooler" on Justia Law

A law enforcement officer’s detailed questions into a driver’s travel plans measurably extended the stop’s duration and were not justified by any reasonable suspicion of or probable cause to believe there was other criminal activity.Defendant moved to suppress the traffic stop evidence, arguing that the officer measurably extended the stop by asking travel plan questions before processing the driver’s license and warrant information. The court granted the motion to suppress, concluding that the officer measurably extended the stop with travel plan questioning unrelated to the traffic violation and that the officer lacked a reasonable suspicion that other criminal activity was occurring to justify the delay. The court of appeals reversed, holding that no constitutional violation occurred because travel plan questions are always within a stop’s scope. The Supreme Court reversed, holding that because there was no colorable, independent justification for the portions of the detention attributable solely to unrelated inquiries into Defendant’s travel plans, this extended detention violated the Fourth Amendment. View "State v. Jimenez" on Justia Law

Holding that the plain language of Kan. Stat. Ann. 38-2273(a) did not provide Grandfather the right to appeal an order denying his motion to terminate the parental rights of his grandson’s parents, the Supreme Court affirmed the dismissal of this appeal for lack of jurisdiction.In this child in need of care action, Grandfather was granted temporary custody of his grandchild. Grandfather then moved for termination of Mother’s and Father’s parental rights or, in the alternative, for an order appointing Grandfather as the child’s permanent custodian. The court found Father unfit and appointed Grandfather as the child’s permanent custodian but declined to terminate Father’s parental rights. Father appealed, and Grandfather cross-appealed the decision not to terminate Father’s parental rights. The court of appeals dismissed Grandfather’s cross-appeal for lack of jurisdiction under the plain language of Kan. Stat. Ann. 38-2273(a), concluding that the statute does not provide the right to appeal when a motion to terminate parental rights has been denied. The Supreme Court affirmed. The dissent disagreed, arguing that the language of section 38-2273(a) does not manifest a legislative intent to make the district court’s ruling, which might “irreparably harm the child,” incapable of correction by a higher court. View "In re T.S." on Justia Law

At issue was whether a criminal defendant’s claim of actual innocence may excuse procedural defaults that would otherwise bar litigation of motions filed under Kan. Stat. Ann. 60-1507.The Supreme Court reversed the decision of the court of appeals affirming the district court’s summary denial of Defendant’s Kan. Stat. Ann. 60-1507 motion and remanded to the district court for an evidentiary hearing on his gateway claim of actual innocence. The motion underlying this appeal was untimely and successive, and to avoid the resulting procedural bars, Defendant argued manifest injustice based on his claim of actual innocence. The Supreme Court held that Defendant’s assertion of actual innocence entitled him to an evidentiary hearing to determine its credibility. Specifically, the Court held that an evidentiary hearing was required to determine whether Defendant’s assertion established manifest injustice or exceptional circumstances sufficient to require the district court to address the merits of his ineffective assistance of counsel claim. View "Beauclair v. State" on Justia Law

The Supreme Court rejected the arguments of Plaintiffs, two public school teachers, who sought a judgment declaring the 2014 amendments to the Teacher Due Process Act, Kan. Stat. Ann. 72-5436 et seq., unconstitutional because the legislation constituted a taking of their property without due process.Before July 1, 2014, the contracts of tenured elementary and secondary teachers in Kansas school districts automatically continued into the next school year unless the school district gave a notice of termination or nonrenewal that set out the reasons for the termination or nonrenewal and notified the teacher of his rights to a due process hearing. The 2014 amendments removed both the requirement that the school district’s Board of Education state its reasons for the termination or nonrenewal and the right to a due process hearing. When Plaintiffs were informed that the Board would not be renewing their teaching contracts, they brought this action. The Supreme Court held that Plaintiffs did not have a property interest that was entitled to constitutional protection under either the federal or state constitution. View "Scribner v. Board of Education of U.S.D. No. 492" on Justia Law

The Supreme Court reversed the court of appeals ruling on Defendant’s motion for a new trial in this criminal case and affirmed Defendant’s conviction for felony burglary and the district court’s denial of Defendant’s motion for a new trial.The court of appeals affirmed Defendant’s conviction but reversed on the question of the effectiveness of Defendant’s counsel, particularly with respect to a conflict of interest when arguing Defendant’s pro se motion for change of counsel prior to sentencing. Because Defendant’s motion for new trial was filed out of time, the court of appeals treated it as a motion under Kan. Stat. Ann. 60-1507. The court of appeals remanded for a hearing, complete with new appointed counsel. The Supreme Court reversed, holding that by granting Defendant a full hearing with new counsel, the court of appeals erroneously provided Defendant with more procedural rights than he may have received if he had filed his motion on time or had filed a true section 60-1507 motion. View "State v. Jarmon" on Justia Law

The Supreme Court affirmed Defendant’s convictions for capital murder and aggravated kidnapping but, as to Defendant’s death sentence, the Court remanded the limited question on intellectual disability to the district court for further proceedings.On appeal, Defendant argued (1) numerous errors occurred during his trial’s guilt phase; and (2) evidence from his 2009 penalty-phase proceedings demonstrated that he was intellectually disabled and that the district court erred when it found insufficient reason to believe that Defendant was intellectually disabled. The Supreme Court remanded the case, holding (1) no reversible error occurred during the trial’s guilt phase; but (2) as to Defendant’s death sentence, new rules for conducting criminal prosecutions have been enacted since Defendant’s trial, and therefore, the best interests of justice require reversing the district court’s reason-to-believe determination and remanding for reconsideration based on current constitutional parameters. View "State v. Thurber" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the decision of the district court, which ordered a reduced term of ten years of postrelease supervision after finding that a sentence of lifetime postrelease supervision would be unconstitutional as applied to Defendant. In reversing, the court of appeals directed the district court to impose lifetime postrelease supervision. The Supreme Court reversed, holding that the district court made a legal error in its analysis and that the court of appeals erred when it did not remand the case for the purpose of using the proper legal standard to consider whether lifetime postrelease supervision was unconstitutional as applied to Defendant. View "State v. Riffe" on Justia Law

The Supreme Court reversed the portion of the court of appeals decision affirming the district court’s order of restitution because neither the district court nor the court of appeals had the advantage of the decision in State v. Arnett, 413 P.3d 787 (Kan. 2018), when calculating or considering the restitution order here.Defendant pleaded no contest to the residential burglary of Ryan Platt’s home. The trial court denied Defendant’s motion to limit restitution to $250 in damage caused to the screen door in the residential burglary and ordered the restitution requested by the State. The Supreme Court reversed the portion of the court of appeals decision upholding the order that Defendant pay $680 for items removed from Platt’s home and vehicle and remanded for a new hearing on restitution, directing the district court to reconsider its calculation of restitution under the standard adopted in Arnett. View "State v. Futrell" on Justia Law