Justia Kansas Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first-degree premeditated murder, aggravated kidnapping, and aggravated robbery. The district court imposed a hard fifty sentence for first-degree murder under Kan. Stat. Ann. 21-4635 without fact-finding by the jury. The Supreme Court affirmed Defendant’s convictions but vacated his hard fifty sentence, holding that Defendant was sentenced in violation of the Sixth Amendment because the district court, rather than the jury, found the existence of aggravating factors by a preponderance of the evidence, rather than beyond a reasonable doubt, in violation of Alleyne v. United States. Remanded for resentencing. View "State v. Mattox" on Justia Law

Defendant was charged with aggravated battery. Defendant moved for a grant of immunity pursuant to Kan. Stat. Ann. 21-5231(a) - the self-defense immunity statute - and asked for a probable cause hearing. The district court granted Defendant’s motion and dismissed the case against Defendant, concluding that he was immune from prosecution under section 21-5231 because, while he used “deadly force,” the presumption of reasonableness applied and the State failed meet its burden to demonstrate probable cause that Defendant’s use of force was not justified. The court of appeals reversed. The Supreme Court reversed the court of appeals and affirmed the district court’s grant of immunity, holding (1) the court of appeals erred by concluding that district courts must resolve evidentiary disputes in favor of the State when ruling on a defendant’s motion for immunity; and (2) the district court’s determination that Defendant was entitled to statutory immunity was both supported by substantial competent evidence and correct as a matter of law. View "State v. Hardy" on Justia Law

After a jury-waived trial, Defendant was convicted of criminal possession of a firearm by a convicted felon. The court of appeals affirmed. Defendant appealed, raising three arguments. The Supreme Court affirmed, holding (1) with regarding to Defendant’s first and third issues, the court of appeals reached the correct conclusions; and (2) Defendant’s argument that his firearm should have been suppressed as evidence because it was obtained through an illegal search of his car was without merit because the search of Defendant’s car was legal under the exigent circumstances plus probable clause exception to the search warrant requirement. View "State v. Howard" on Justia Law

At issue in this case was the interpretation of the procedural requirements that the Kansas Probate Code sets for parties petitioning for probate. Specifically, this appeal concerned a contest between the disinherited son (Son) of the decedent and the son’s daughters (Granddaughters), who were the beneficiaries under the decedent’s will. In its final order, the district court held that the decedent’s estate passed under the will to the Granddaughters in equal shares. The Supreme Court affirmed the analysis and conclusions of both the district court and the court of appeals as to the issues raised in an appeal and petition for review, holding (1) an order setting aside the order admitting the will to probate did not end the proceeding; (2) the district court did not commit reversible error in concluding that the Granddaughters timely commenced a probate proceeding; and (3) the district court did not commit reversible error when it refused to find that a putative 1997 will revoked the 1992 will. View "In re Estate of Rickabaugh" on Justia Law

In 2013, Michael Clare shot and killed his wife, Deborah Clare, and then took his own life. Jessica Crosslin, Deborah’s biological daughter, filed a petition for letters of examination seeking to file a claim against Michael’s estate under the Kansas Probate Code. Crosslin was subsequently appointed administrator of Deborah’s estate, and Christine Clare, Michael’s aunt, was appointed administrator of Michael’s estate. The district court determined that Crosslin had failed to satisfy a statutory time limitation for filing a claim against the estate because she failed to obtain a written, signed judicial order setting the matter for hearing. The court cited specific local rules with which Crosslin apparently did not comply. The court of appeals affirmed. The Supreme Court reversed, holding that the local rules did not consistently preclude Crosslin from following the procedures that she took, the local rules conflicted with certain statutory requirements, and local rules that add requirements to the statutory scheme and create jurisdictional obstacles are invalid. View "In re Estate of Clare" on Justia Law

Defendant was convicted of one count of first-degree felony murder, multiple counts of fleeing or attempting to elude, and two counts of theft. Defendant was sentenced to life imprisonment for the felony murder conviction. The Supreme Court affirmed the convictions and sentences, holding (1) the district court judge did not abuse its discretion in denying Defendant’s motion to sever the crimes by date; (2) the district court judge did not err in failing to instruct the jury on lesser degrees of felony murder; and (3) the district court judge did not err in relying on Defendant’s criminal history score to enhance Defendant’s sentencing without requiring the criminal history to be included in the charging document and proved to a jury beyond a reasonable doubt. View "State v. Ritz" on Justia Law

After a jury trial, Defendant was convicted of aggravated robbery and aggravated assault. The district court sentenced Defendant to 245 months’ imprisonment. The court of appeals affirmed. Defendant later filed a request for postconviction DNA testing pursuant to Kan. Stat. Ann. 21-2512(a). The district court entered an order granting postconviction DNA testing. Before the testing was conducted and before any posttesting court proceedings were completed, the State brought an appeal “upon a question reserved” pursuant to Kan. Stat. Ann. 22-3602(b)(3). The court of appeals concluded that it lacked jurisdiction over the appeal because there had been no final judgment when the State appealed. The Supreme Court affirmed, holding that the district court’s order granting testing was not a final order and could not be appealed by the State upon a question reserved, and therefore, the court of appeals lacked jurisdiction to hear the merits of the case. View "State v. LaPointe" on Justia Law

In 2010, Plaintiffs filed an action claiming that the State violated Kan. Const. art. VI, 6(b) by inequitably and inadequately funding K-12 public education. A three-judge panel determined that, through the School District Finance and Quality Performance Act (SDFQPA), the State had inequitably and inadequately funded education in violation of Article 6. On appeal, the Supreme Court affirmed the panel on equity but determined that the panel did not apply the correct standard in concluding that the State violated the adequacy component. On remand, the panel declared the financing under the SDFQPA and the subsequently enacted Classroom Learning Assuring Student Success Act (CLASS), which replaced the SDFQPA, to be constitutionally inadequate. The Supreme Court affirmed, holding that the panel correctly found that the financing system is constitutionally inadequate. As a remedy, the Court stayed the issuance of today’s mandate and ordered that, by June 30, 2017, the State must demonstrate that any K-12 public education financing system the legislature enacts is capable of meeting the adequacy requirements of Article 6. Otherwise, a lifting of the stay of today’s mandate will mean that the State’s education financing system is constitutionally invalid and therefore void. View "Gannon v. State" on Justia Law

In two separate cases, Defendant was convicted of first-degree premeditated murder and attempted first-degree murder. The district court imposed a hard twenty-five sentence for the first-degree murder and a 165-month sentence for the attempted first-degree murder, to run consecutively. The district court ordered restitution in the amount of $12,406. The court did not order Defendant to begin paying the restitution while in prison. Defendant appealed, arguing that the district court abused its discretion when it determined that a restitution plan would not be unworkable. The Supreme Court affirmed, holding that a reasonable person would not conclude that a restitution plan was unworkable under the facts of this case. View "State v. Holt" on Justia Law

The Subcontractor for a hotel construction project obtained materials for its part of the project from Supplier but failed to pay for them. Supplier claimed a lien against the hotel property. Because Supplier’s filing placed a cloud on the title, affecting the hotel owner’s refinancing, the General Contractor filed a bond with the district court to secure payment of Supplier’s claim. The district court approved the bond, which discharged the lien. Supplier then filed suit for payment for the materials it had supplied for the hotel. The district court granted summary judgment to the General Contractor. The court of appeals reversed and directed that judgment be granted to Supplier. The Supreme Court affirmed, holding that Kan. Stat. Ann. 60-1110 discharged the lien when the approved bond was filed, and any defenses General Contractor may have had against the lien filing had no relevance now. View "Wagner Interior Supply of Wichita, Inc. v. Dynamic Drywall, Inc." on Justia Law