Justia Kansas Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of capital murder for the killings of Darren Wornkey and Mikiala Martinez and other related crimes. The jury sentenced Defendant to death for the capital offense. The court of appeals affirmed Defendant’s convictions but vacated his death sentence, concluding that the Eighth Amendment required informing Defendant’s jury that mitigating circumstances need not be proven beyond a reasonable doubt. The United States Supreme Court reversed and returned Defendant’s case to the Supreme Court for further proceedings because there were unresolved penalty phase issues. The Supreme Court affirmed Defendant’s death sentence, holding that the outstanding issues did not require reversal or remand. View "State v. Gleason" on Justia Law

This case arose from an eminent domain proceedings in Douglas County. The Secretary of Transportation condemned a property in Lawrence owned by Doug Garber Construction, Inc. (Garber) to facilitate construction of the South Lawrence Trafficway (SLT). Garber disputed the amount of compensation, and the case proceeded to trial. The jury determined that the value of the property was $112,000. Garber appealed, arguing that the district court erred by issuing two orders in limine that excluded certain valuation testimony. The Supreme Court affirmed, holding that the district court did not abuse its discretion in excluding the testimony at issue. View "Doug Garber Construction, Inc. v. King" on Justia Law

After a jury trial, Defendant was convicted of first-degree felony murder for the killing of the victim during the attempted distribution of marijuana. The Supreme Court affirmed, holding (1) Defendant waived or abandoned his challenge to evidence that he was growing marijuana in his basement as well as evidence of prior sales by the victim at or near his house; (2) there was a sufficient causal relationship between the victim’s death and the attempted sale of marijuana; (3) the district court did not err in denying Defendant’s requested self-defense instruction; and (4) the district court did not err by failing to give a unanimity instruction. View "State v. Beltz" on Justia Law

In 2003, Mid America Ag Network, Inc. (MAAN, Inc.) and Journal Broadcast Group of Kansas, Inc. (JBGK) entered into a settlement agreement governing dealings between the companies. The agreement contained a clause stating that neither party shall assign the agreement without prior written consent of the other party. In 2005, MAAN, Inc. allegedly sold the agreement and its right to do business under the MAAN name to Steckline Communications, Inc. (SCI) without JBGK’s consent. SCI and JBGK continued to do business with each other pursuant to the agreement’s terms until 2012. That year SCI sued JBGK for breaching the agreement. The district court dismissed the suit on the grounds that SCI lacked standing because it was not a party to the contract. The Supreme Court reversed, holding that the district court erred in granting JBGK’s motion to dismiss because SCI set forth a colorable claim that JBGK was equitably estopped from asserting that SCI lacked standing on the grounds of an inadequate assignment. Remanded. View "Steckline Communications, Inc. v. Journal Broadcast Group of Kansas, Inc." on Justia Law

Mark Byers, who worked as a grinder at Acme Foundry, was injured in a workplace accident. After Byers was released from the hospital he agreed to do a drug test. Byers’ urine sample was thrown into the trash, however, when Acme’s in-house nurse determined that there was not enough urine in the collection cup. An administrative law judge concluded that Byers forfeited his benefits under the Workers Compensation Act by providing an inadequate urine sample for testing. The Workers Compensation Board upheld that ruling. The Supreme Court reversed, holding that Byers’ actions did not amount to a refusal. Remanded. View "Byers v. Acme Foundry" on Justia Law

Plaintiffs were the heirs of two individuals who were killed in a single-vehicle accident. Plaintiffs brought this wrongful death action against Cowley County, Bolton Township, and the Kansas Department of Wildlife, Parks and Tourism for failure to provide adequate warnings, signs or barriers on portions of the road where the accident occurred. The district court granted partial summary judgment to the County and full summary judgment to the Township and the Kansas Department of Wildlife. The Supreme Court affirmed in part and reversed in part, holding (1) the County did not have a duty to initiate an engineering study; (2) the County is immune from liability under the discretionary judgment exception of the Kansas Tort Claims Act (KTCA) but not immune from liability under the recreational exception of the KTCA for any failure to place an advisory speed plaque or warnings sings on its portion of 322nd Road; (3) the Township had no duty to place traffic control devices or other warning signs on its portion of 322nd Road; and (4) the KTCA exception for failing to inspect the property of another does not apply to the facts presented in this case. View "Patterson v. Cowley County, Kansas" on Justia Law

After a jury trial, Defendant was found guilty of unlawful distribution of controlled substances and conspiracy to distribute controlled substances. The district court sentenced Defendant to sixty-eight months in prison and thirty-six months’ postrelease supervision. The Supreme Court affirmed, holding that the district court did not err (1) by failing to issue a unanimity instruction on the conspiracy charge; (2) by failing to grant Defendant’s directed verdict based on insufficiency of the evidence on all charges; and (3) in instructing the jury that the mens rea for the distribution of controlled substances charges was knowingly. View "State v. Cottrell" on Justia Law

The one-subject rule in Article 2, Section 16 of the Kansas Constitution provides that “[n]o bill shall contain more than one subject, except appropriation bills an bills for revision or codification of statutes.” At issue in this case was whether 2014 Senate Substitute for House Bill No. 2506 violates the one-subject rule. Kansas National Education Association (KNEA) argued that the bill violates the one-subject rule because it contains both appropriations and substantive general legislation. The district court dismissed the complaint, concluding that KNEA failed to state a claim as a matter of law because H.B. 2506 did not violate Article 2, Section 16. The Supreme Court affirmed, holding (1) KNEA had standing to bring this lawsuit, and its claim is ripe; (2) Article 2, Section 16 does not forbid combining appropriations and general legislation into one bill, provided that all provisions of that bill address the same subject; and (3) H.B. 2506’s provisions relate to one subject. View "Kansas National Education Ass’n v. State" on Justia Law

After a jury trial, Defendant was convicted of felony murder and child abuse. The Supreme Court affirmed, holding (1) the district court did not err by admitting fourteen autopsy photographs of the victim; (2) the district court did not err by excluding evidence about a medical malpractice lawsuit the victim’s mother filed against a doctor who treated the victim before her death; (3) the prosecutor did not improperly bolster the mother’s credibility as a witness during opening remarks and in the examination of other witnesses; and (4) the district court did not err by failing to instruct the jury sua sponte on unintentional second-degree murder as a lesser included offense of felony murder. View "State v. Love" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and conspiracy to commit first-degree murder. Defendant appealed, arguing that the district court erred in denying his motion for new trial because the State committed a Brady violation by failing to disclose a police report to the defense before trial. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant’s motion for new trial because it cannot be concluded there was a reasonable probability that, had the report been timely disclosed to the defense, the trial result would have been different. View "State v. DeWeese" on Justia Law