Justia Kansas Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s conviction for felony murder, holding that sufficient evidence supported the conviction even where the State charged Defendant as the killer but the trial evidence established that his cousin fired the fatal shot.The Court held (1) because the trial record provided sufficient evidence that Defendant participated in the crime of an aggravated burglary during which an individual was killed, and because the issue of whether Defendant was the triggerman bore no relevance to that determination, a rational factfinder could have found Defendant guilty of felony murder beyond a reasonable doubt; (2) the felony-murder elements instruction was not overly broad; and (3) any alleged error in the felony-murder elements instruction was harmless. View "State v. Robinson" on Justia Law

The Supreme Court affirmed Defendant’s convictions of aggravated burglary and first-degree felony murder.Defendant was charged with aggravated burglary and first-degree felony murder. A jury convicted Defendant of aggravated burglary but failed to reach a verdict on the felony-murder charge. The jury hung after a second trial. A third jury convicted Defendant of felony murder.The Supreme Court affirmed, holding (1) the district judge erred by communicating with jurors, outside Defendant’s presence, during the third trial about notes found in the jury room, but there was no reasonable possibility that the error affected the verdict; (2) the district judge erred by shredding notes found in the jury room without first showing the notes to Defendant and his attorney, but Defendant did not show reversible error; (3) the district judge did not err during the third trial by admitting evidence of Defendant’s interview with law enforcement officers because Defendant voluntarily waived his Miranda rights; (4) the district judge did not err in its response to a jury question asked during the first trial; and (5) reversal was not required under the cumulative error doctrine. View "State v. Walker" on Justia Law

At issue was whether the State’s remedial legislation, the Kansas School Equity and Enhancement Act (KSEEA), enacted by 2017 Senate Bill 19, met the adequacy requirement of Kan. Const. art. VI, 6(b).In Gannon v. State, 402 P.3d 513 (Kan. 2017) (Gannon V), the Supreme Court held that the State had not met its burden of showing that KSEEA met the adequacy and equity requirements of Article 6. The Court stayed its mandate until June 30, 2018 to give the State ample time to satisfactorily demonstrate that its additional remedial legislation brought the K-12 public education financing system into constitutional compliance. Although the State has still not met the adequacy requirement in Article 6, the Court held that the State has corrected the Gannon V constitutional infrmities and created no others. The Court retained jurisdiction and stayed the issuance of today’s mandate until June 30, 2019, or until further order of the court. Therefore, KSEEA will remain in temporary effect. View "Gannon v. State" on Justia Law

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