Justia Kansas Supreme Court Opinion Summaries

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

Defendant was convicted of felony murder, two counts of child abuse, and one count of interference with a law enforcement officer. Defendant appealed, arguing, inter alia, that the district court improperly admitted statements Defendant gave to police after he allegedly invoked his right to counsel and that the statements were involuntary. The Supreme Court affirmed, holding (1) Defendant knowingly and intelligently waived his previously-invoked right to counsel, and Defendant’s subsequent inculpatory remarks were freely and voluntarily given; (2) the district court properly refused to give lesser included offense instructions on the felony-murder charge; (3) the evidence was sufficient to sustain Defendant’s conviction of interference with a law enforcement officer; and (4) there were substantial and compelling reasons to impose upward departure sentences for the child abuse convictions. View "State v. Brown" on Justia Law

Defendant pleaded no contest to premeditated first-degree murder. Before sentencing, Defendant filed a motion requesting that the district court determine if he was a person with “intellectual disability.” The court denied the motion. Defendant was sentenced to a hard twenty-five life sentencing. During the pendency of this appeal, the legislature amended the statute that supplies part of the definition of intellectual disability in Kan. Stat. Ann. 21-6622(b). The Supreme Court reversed, holding that, under the circumstances of this case, the recent amendments require consideration by the district court in its intellectual disability calculus. Remanded with instructions. View "State v. Corbin" on Justia Law

After a jury trial, Defendant was convicted of one count each of aggravated robbery, rape, aggravated criminal sodomy, kidnapping, and aggravated kidnapping. The court of appeals affirmed the convictions. In the following years, Defendant filed numerous state and federal claims, all without success. Defendant subsequently filed a motion seeking relief under Kan. Stat. Ann. 60-1507, asserting that his retained counsel in a previous section 60-1507 action had provided ineffective assistance in prosecuting his appeal. The district court denied the motion. The court of appeals affirmed without addressing the merits, ruling that the motion in the present case was filed more than one year after the mandate issued in the previous case and, therefore, Defendant was precluded from bringing the present action as a matter of law. Defendant appealed. The Supreme Court remanded, holding that, under the circumstances, the district court properly found an essential fact that was necessary to support its judgment on the merits, and therefore, the case must be remanded for the court of appeals to resolve the issue raised by Defendant in his brief. View "McIntyre v. State" on Justia Law