Justia Kansas Supreme Court Opinion Summaries

The case revolves around William P. Spangler, who was initially convicted of second-degree murder for his role in the shooting death of Faustino Martinez. After serving a prison term longer than his sentence, Spangler was retried and convicted of a lesser charge, involuntary manslaughter. He then sought compensation for the extra time he spent in prison.Spangler's initial conviction was upheld by the Court of Appeals. However, he later filed a motion arguing that he received constitutionally deficient assistance of counsel. The district court agreed, finding that Spangler's trial counsel failed to investigate his mental health status and its effect on his state of mind when he shot Martinez. This failure was deemed prejudicial to Spangler, and a new trial was ordered. The Court of Appeals affirmed this decision.In the retrial, Spangler was again convicted, but this time of involuntary manslaughter rather than second-degree murder. He was released based on time served, having served about four-and-a-half years beyond the sentence imposed for his involuntary manslaughter conviction. Spangler then filed a civil action seeking compensation for the time he spent in prison beyond his involuntary manslaughter sentence.The Supreme Court of the State of Kansas affirmed the district court's decision that Spangler's own conduct caused or brought about his conviction, thus precluding any recovery. The court interpreted the statute to reflect the Legislature's intent to impose a common-sense limitation: Only someone innocent of the criminal conduct supporting the underlying conviction may pursue a claim for damages. Therefore, a claimant like Spangler, who stands convicted of a lesser included offense based on the same charge as a previous conviction, is not eligible to seek relief. View "In re Wrongful Conviction of Spangler" on Justia Law

The case revolves around Jose Garcia-Martinez, who was convicted for first-degree felony murder, aggravated kidnapping, aggravated battery, and battery. The incident occurred on July 1, 2020, when Garcia-Martinez and others attacked Roy Hayden, suspecting him to be a law enforcement officer. The group beat Hayden, confined him in a bathroom, and later moved him to the trunk of a car. Hayden's decomposed body was found days later in the abandoned car.The case was initially tried in Sedgwick District Court, where Garcia-Martinez was found guilty. He appealed his convictions, arguing that the State presented alternative means of committing aggravated kidnapping and that the evidence was insufficient to support a finding of guilt on each of the alternative means. He also argued that the district court erred in refusing to give a unanimity instruction because the jury heard evidence of multiple acts that could have supported his aggravated kidnapping conviction.The Supreme Court of the State of Kansas affirmed the lower court's decision. The court held that the phrase "taking or confining" in K.S.A. 21-5408(a) does not present alternative means of committing kidnapping and aggravated kidnapping; rather, it presents options within a means merely describing the factual circumstances that may prove the material element of holding the victim to accomplish one of the four alternative means of committing kidnapping set forth in the statute. The court also found that a unanimity instruction was not required because the evidence established a single continuous incident of aggravated kidnapping, not multiple acts. View "State v. Garcia-Martinez" on Justia Law

Shana L. Jarmer was arrested for driving under the influence (DUI) after failing a breath alcohol test. At the time of the arrest, Jarmer was in the driver's seat of a vehicle stuck in a muddy ditch. Despite her efforts to move the vehicle, it remained stationary due to the muddy conditions. Following her arrest, Jarmer was notified that her driving privileges would be suspended by the Kansas Department of Revenue (KDR) under K.S.A. 2020 Supp. 8-1014. Jarmer challenged the suspension, arguing that she was merely attempting to operate the vehicle, not actually operating it, as the vehicle was not moving.The KDR upheld the suspension, finding that Jarmer was operating the vehicle. Jarmer sought judicial review of this decision in Sumner County District Court, which denied her petition, agreeing with the KDR that Jarmer was operating the vehicle since the engine was running, she was behind the wheel, and the tires were spinning. On appeal, the Kansas Court of Appeals affirmed the district court's decision, concluding that Jarmer operated the vehicle because she caused it to function or work when she engaged the transmission and pressed the gas pedal.The Supreme Court of the State of Kansas reversed the decisions of the lower courts. The Supreme Court held that to "operate" a vehicle means to "drive" it, which requires motion on the part of the vehicle. The court found that while Jarmer unquestionably attempted to operate the vehicle, her car did not move, despite her best efforts. Therefore, it was factually impossible for Jarmer to "move"—and, under the court's precedent, "operate"—the vehicle. The court concluded that Jarmer's unsuccessful effort to drive her car out of a muddy ditch fails to satisfy K.S.A. 8-1002(a)(2)(A)'s requirement that she was "operating a vehicle while under the influence of alcohol or drugs, or both." The court reversed the suspension of Jarmer's driver's license and remanded the matter to the KDR for further proceedings. View "Jarmer v. Kansas Dept. of Revenue" on Justia Law

The Supreme Court of Kansas affirmed the conviction of Kylie Jo Elizabeth Waldschmidt for aiding and abetting felony murder and interference with a law enforcement officer. Waldschmidt was involved in a romantic relationship with Diego Gallaway, the victim, and Ryan Thompson, the person who killed Gallaway. The court found that Waldschmidt's actions, including discussing plans to confront Gallaway, driving Thompson to pick up a gun, and driving him to Gallaway's apartment, constituted aiding and abetting in the commission of the crime.The lower court had rejected Waldschmidt's claim that the predicate felonies of aggravated assault and aggravated battery were not distinct from the killing and thus should be merged. The Supreme Court of Kansas agreed with the lower court, finding that the evidence presented at trial was sufficient for the jury to conclude that the acts of displaying the gun and placing Gallaway in a headlock were distinct from the act that killed Gallaway.The Supreme Court also found that the district court did not err in failing to instruct the jury on the use of force in defense of a person or in defense of an occupied vehicle. The court held that while these instructions would have been legally appropriate, their omission was not clearly erroneous and therefore could not be assigned as error on appeal.The court also found that the prosecutor committed two errors: bolstering the credibility of the State's witnesses and personally commenting on Waldschmidt's testimony. However, the court held that these errors did not deprive Waldschmidt of a fair trial. The court also held that an unpreserved instructional issue that is not clearly erroneous cannot be considered in a cumulative error analysis. View "State v. Waldschmidt" on Justia Law

Tracey Murray and the Estate of Robert Murray filed a lawsuit against Miracorp, Inc., NTTS, Inc., Lane Goebel, and Shane Goebel, alleging both legal and equitable claims based on conduct that took place before 2012. The Murrays claimed that they were shareholders in Miracorp and that the company and its officers had breached fiduciary duties, committed fraud, and unjustly enriched themselves at the Murrays' expense. The Murrays also alleged that Miracorp had converted their property and misappropriated trade secrets.The district court granted summary judgment in favor of Miracorp, ruling that the Murrays' claims were barred by the applicable statutes of limitations. The court found that the Murrays' injuries were reasonably ascertainable in 2011, and thus, the period for filing a lawsuit had expired. The Murrays appealed this decision.The Kansas Court of Appeals affirmed the district court's decision. The appellate court agreed that the Murrays' claims were time-barred because their injuries were reasonably ascertainable in 2011. The court held that the Murrays had waited too long to investigate and seek redress for their injuries.The Kansas Supreme Court affirmed the decisions of the lower courts. The court held that the Murrays had a duty to reasonably investigate their suspicions in 2011. The court found that the Murrays did nothing to investigate their suspicions until 2016, which was unreasonable. As a result, the court ruled that the Murrays' claims were barred by the statute of limitations. View "Murray v. Miracorp, Inc." on Justia Law

The case revolves around Gerald D. Hambright, who was charged with unlawful possession of a weapon, specifically a dagger, as a felon. The charge was based on an encounter with a sheriff's deputy, during which Hambright was found to have an object in a sheath on his belt. The object was later identified as a dagger. Hambright had a prior felony conviction, which prohibited him from possessing a weapon. The State initially charged Hambright with unlawful possession of a knife, but later amended the charge to unlawful possession of a dagger.The case was first heard in the Sedgwick District Court, where Hambright was convicted. Hambright appealed to the Court of Appeals, arguing that the State failed to present sufficient evidence that he possessed a dagger. The Court of Appeals agreed with Hambright, holding that the State failed to present sufficient evidence of what characteristics made the object a dagger. The Court of Appeals reversed the district court's decision, leading to the State's appeal to the Supreme Court of the State of Kansas.The Supreme Court of the State of Kansas disagreed with the Court of Appeals' decision. The Supreme Court held that the State presented sufficient evidence for a jury to determine beyond a reasonable doubt that Hambright possessed a dagger. The jury had seen the dagger and heard details about its characteristics, including its sharp edge and pointed end. The Supreme Court reversed the Court of Appeals' decision, affirmed the district court's judgment on the single issue, and remanded the case to the Court of Appeals for consideration of other issues raised by Hambright that the Court of Appeals had not addressed. View "State v. Hambright" on Justia Law

In this case from the Supreme Court of Kansas, the defendant, D.W., was convicted of premeditated first-degree murder and criminal discharge of a firearm at an occupied vehicle. The defendant was in the passenger seat of a vehicle when an accomplice in the backseat shot and killed the 16-year-old driver of the car they were pursuing. The defendant was sentenced to life without parole for 50 years and appealed his conviction and sentence.On appeal, the defendant argued that the trial court erred in admitting bodycam footage showing the victim's dying moments, asserting it warranted a new trial. He also claimed that the court imposed an illegal sentence by ordering lifetime post-release supervision on his murder conviction.The Supreme Court disagreed with both arguments. The court determined that the bodycam footage was relevant and its probative value outweighed the risk of undue prejudice. The court also found that the lower court had imposed a term of lifetime parole, not lifetime post-release supervision, which conformed with the applicable sentencing statute. Therefore, the court affirmed the defendant's convictions and sentence. View "State v. D.W." on Justia Law

In this decision from the Supreme Court of the State of Kansas, the defendant, Jerome Edwards, appealed the denial of his 2022 motion for DNA testing. Edwards had previously filed similar motions in 2011, 2018, and 2022 asking for DNA testing of biological materials on a cigarette butt and a bullet, both of which were denied. He argued that the district court erred by applying the "law of the case" doctrine to deny his 2022 motion, stating that the court did not have jurisdiction over his case when it denied the 2018 motion as he had an appeal pending at the same time.The Supreme Court held that K.S.A. 21-2512, the law governing DNA testing, grants the district court jurisdiction to consider and act on a motion seeking DNA testing even after an appeal has been docketed. This conclusion was based on the plain language of the law, which allows a defendant to seek DNA testing "at any time" and "[n]otwithstanding any other provision of law." The court also held that the law of the case doctrine applied to the defendant's 2022 motion, as it sought DNA testing of the same evidence as his 2018 motion. Therefore, the district court correctly applied the law of the case doctrine to deny Edwards' 2022 motion for DNA testing. Finally, the court affirmed the district court's decision. View "State v. Edwards" on Justia Law

In Kansas, Miles Loren Martin was convicted of possession of methamphetamine and possession of a controlled substance without a drug-tax stamp. Martin appealed, arguing that these convictions violated constitutional protections against double jeopardy and a Kansas statute prohibiting multiple convictions for the same conduct.The Kansas Supreme Court rejected Martin's argument. It held that possession of methamphetamine and failure to affix a drug-tax stamp were not the same offenses under the Kansas statute, because the former carried a higher penalty than the latter, and because the latter required an element (failure to affix the stamp) not required for the former. Consequently, the legislature had not prohibited multiple punishments for these offenses.The court also held that Martin's convictions did not violate the Double Jeopardy Clauses of the U.S. and Kansas Constitutions. It reasoned that the legislature intended to impose multiple punishments for the offenses because they targeted different conduct (possession of an illegal narcotic versus failure to pay a drug tax) and carried different penalties.On Martin's challenge to the search of his pill bottle, the court found that the search fell within the exception for a search incident to a lawful arrest. The court noted that the officer had a legitimate basis to arrest Martin before the search and that the arrest followed shortly after the search. The court also found that the search of the bottle did not exceed the permissible scope of a search incident to arrest. View "State v. Martin" on Justia Law

In the case before the Supreme Court of the State of Kansas, the appellant, Gabrielle Griffie, appealed her conviction for unlawful assembly under Wichita Municipal Code of Ordinances (W.M.O.) § 5.73.030(1). The conviction was premised on the City of Wichita's disorderly conduct ordinance, W.M.O. § 5.24.010, which defines disorderly conduct as "one or more of the following acts that the person knows or should know will alarm, anger or disturb others or provoke an assault or other breach of the peace", including "using fighting words or engaging in noisy conduct tending to reasonably arouse alarm, anger or resentment in others."Griffie challenged the constitutionality of the "noisy conduct" provision, arguing it was unconstitutionally overbroad under the First Amendment. Both the district court and the Court of Appeals held the provision constitutional. However, the Supreme Court of the State of Kansas disagreed. Applying the substantial overbreadth doctrine used by Kansas courts to adjudicate First Amendment overbreadth challenges, the court concluded the "noisy conduct" provision within W.M.O. § 5.24.010(c) is unconstitutionally overbroad because it prohibits a substantial amount of protected activity in relation to the provision's plainly legitimate sweep.However, the court found that it was not necessary to strike the entire subsection, as there was a satisfactory method of severing the unconstitutional "noisy conduct" provision from the constitutional "fighting words" provision within the same subsection. Accordingly, the court reversed the judgments of the Court of Appeals and the district court. View "City of Wichita v. Griffie" on Justia Law