Justia Criminal Law Opinion Summaries

Articles Posted in Kansas Supreme Court
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A few days after Thanksgiving in 2018, Zshavon Malik Dotson shot and killed his friend Ronald "R.J." Marks Jr. at R.J.'s home in Kansas City. Dotson and R.J. had struggled over R.J.'s rifle, and Dotson shot R.J. in the kitchen after gaining control of the weapon. Dotson claimed he acted in self-defense, while R.J.'s mother, Carolyn Marks, testified that Dotson was the aggressor. A jury found Dotson guilty of first-degree premeditated murder and aggravated battery.The Wyandotte District Court, presided over by Judge Wesley K. Griffin, sentenced Dotson to life imprisonment with no chance of parole for 25 years. Dotson appealed, arguing insufficient evidence of premeditation, prosecutorial misconduct, ineffective assistance of counsel, and errors in jury instructions. He also contended that first-degree premeditated murder and second-degree intentional murder are identical offenses under Kansas law.The Kansas Supreme Court reviewed the case and affirmed Dotson's convictions. The court held that sufficient evidence supported the jury's finding of premeditation, noting Dotson's actions before and during the struggle. The court acknowledged minor prosecutorial misstatements about premeditation but deemed them harmless beyond a reasonable doubt. The court also found no merit in Dotson's claims of ineffective assistance of counsel, as he failed to show that any alleged deficiencies affected the trial's outcome. Additionally, the court ruled that the jury instructions were legally sufficient and not misleading. Finally, the court rejected Dotson's identical-offense argument, reaffirming that premeditated first-degree murder and intentional second-degree murder are not identical offenses under Kansas law. View "State v. Dotson" on Justia Law

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Ryan Reynolds broke into his estranged wife's house, armed with a handgun, and confined his wife, their daughter, and his wife's sister-in-law, threatening to kill them. The two women escaped with the child, and police apprehended Reynolds as he was leaving. A jury convicted him of multiple crimes, including aggravated burglary and aggravated endangering a child.The Shawnee District Court sentenced Reynolds to 180 months in prison. Reynolds appealed, challenging his convictions for aggravated burglary and aggravated child endangerment. The Kansas Court of Appeals affirmed these convictions but reversed his criminal threat conviction. Reynolds and the State both sought further review.The Kansas Supreme Court reviewed the case and agreed with Reynolds that the district court presented the aggravated burglary charge as an alternative means crime by referring to both a building and a dwelling. However, the court rejected the automatic reversal rule from State v. Wright, which required substantial evidence for each means. Instead, the court adopted a harmless error analysis, concluding that the jury would have reached the same verdict even without the error. The court also held that the aggravated burglary instruction listing three felonies (kidnapping, aggravated assault, or criminal threat) was legally and factually appropriate.Regarding the aggravated endangering a child charge, the court found no error in the jury instruction, despite Reynolds' argument that "causing or permitting" created alternative means. The court held that the instruction was legally and factually appropriate.The Kansas Supreme Court affirmed the judgments of the Court of Appeals and the Shawnee District Court on the issues subject to review. View "State v. Reynolds" on Justia Law

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The case involves Davontra Alston, who was convicted of premeditated first-degree murder, felony first-degree murder, conspiracy to commit first-degree murder, and criminal discharge of a firearm at an occupied vehicle for his role in the 2020 shooting death of D'Angelo Payne in Topeka. The State's theory was that Alston conspired with Diquan Clayton, his cousin, and James Boatwright to murder Payne and that he aided and abetted Boatwright and others in the murder. The State built a circumstantial case based on evidence that Clayton and Alston resented Payne's relationship with Danielle Morrison and they felt Payne had disrespected Morrison, Alston, and his family.The district court denied Alston's motion to dismiss the murder and conspiracy convictions as multiplicitous. Alston argued his conviction for conspiracy to commit premeditated murder "covers all the conduct alleged by the State which was attributable directly to" him and his remaining three convictions should be set aside. Alston also filed a motion for a new trial, alleging several trial errors. The district court denied both motions but determined Alston's felony murder conviction merged with his first-degree premeditated murder.In the Supreme Court of the State of Kansas, Alston argued that his conviction for premeditated first-degree murder under an aiding and abetting theory is duplicitous of his conviction for conspiracy to commit first-degree murder. He also contended that the district court abused its discretion in denying his motion for a new trial in which he argues the State mischaracterized evidence, the district court erroneously admitted hearsay evidence, and the State committed prosecutorial error. The court rejected Alston's claims and affirmed his convictions. View "State v. Alston" on Justia Law

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David Cornell Bennett Jr. pleaded guilty to one count of capital murder and three counts of premeditated first-degree murder in December 2017. As part of the plea agreement, Bennett waived his appellate rights. In June 2020, Bennett filed a pro se motion requesting a hearing under State v. Ortiz, alleging that his appointed counsel failed to file an appeal as requested following his sentencing hearing. The State argued that Bennett had already waived his appellate rights under the plea agreement. The district court denied Bennett's motion, finding that Bennett had knowingly waived his appellate rights.The district court's decision was appealed to the Supreme Court of the State of Kansas. Bennett argued that his waiver of appellate rights was ambiguous and that he was entitled to a late appeal under the criteria set forth in Ortiz. The Supreme Court reviewed the facts underlying the district court's ruling for substantial competent evidence and the legal conclusion made by the district court on those facts as to whether the exception applies was reviewed de novo.The Supreme Court found that Bennett was properly informed of his rights and what he was waiving. The court noted that Bennett received the sentence contemplated in the plea agreement and filed no timely appeal. The court also found that Bennett had not explained why he should be allowed to appeal on any grounds two and a half years out of time. The court concluded that Bennett had not shown that he could qualify for a late appeal under the Ortiz criteria. The Supreme Court affirmed the decision of the district court, denying Bennett's motion for a late appeal. View "State v. Bennett" on Justia Law

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Darrick S. Harris, serving a life sentence for first-degree murder and aggravated battery committed during a prison riot in 1993, petitioned the district court for forensic testing of objects used in the murder under K.S.A. 21-2512. Harris hoped to find unknown biological material on these objects that could be subject to DNA testing. However, the State claimed it no longer had possession of the items. The district court ruled Harris' motions moot as the items he sought to test were no longer in the State's possession. Harris then filed a motion requesting discharge from incarceration, alleging that the State's inability to comply with his request for DNA testing created an adverse inference that his DNA was not present, which should be deemed sufficient to constitute exoneration. The district court denied this motion, holding there was no evidence the State acted in bad faith in failing to preserve the evidence.Harris appealed to the Supreme Court of the State of Kansas, arguing that the State's failure to retain physical evidence violated his due process rights. He also argued that the district court erred by not ordering the DNA testing of the biological material that was in the State's possession. The Supreme Court dismissed the second issue, stating that Harris had explicitly informed the court he was not seeking testing of the swabs.Regarding Harris' spoliation claim, the Supreme Court affirmed the district court's decision, but for different reasons. The court held that K.S.A. 21-2512 does not provide a vehicle for a claim on the facts presented by Harris. The court also noted that Harris' claim, even if construed as a motion under K.S.A. 60-1507, was procedurally barred by the one-year time limitation of K.S.A. 2023 Supp. 60-1507(f), and Harris had presented no argument for an exception. Therefore, the Supreme Court affirmed the district court's denial of Harris' motion. View "State v. Harris " on Justia Law

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Cody Michael Lamia-Beck pleaded no contest to second-degree murder and was sentenced by the district court. However, the court later ruled that the sentence was illegal because it was generated from an incorrect sentencing grid and resentenced Lamia-Beck to a longer sentence. Lamia-Beck appealed, arguing that the original sentence was legal because it fell within the correct sentencing range, and therefore, the district court lacked jurisdiction to impose a new one.The district court had initially sentenced Lamia-Beck based on a sentencing range that corresponded with the drug offense grid rather than the nondrug offense grid. The State moved to correct the sentence, arguing that it was illegal because it was not the high number in the correct grid block. The district court agreed with the State and resentenced Lamia-Beck to a longer sentence. Lamia-Beck appealed this decision, but the Court of Appeals affirmed the district court's ruling.The Supreme Court of the State of Kansas affirmed the decisions of the lower courts. The Supreme Court held that under the Revised Kansas Sentencing Guidelines Act, a sentence is presumptively illegal if it is drawn from an incorrect sentencing grid block. The court found that the original sentence did not conform to the applicable statutory provision in character or punishment, making it illegal. The court rejected Lamia-Beck's argument that the sentence was legal because it fell within the correct sentencing range, stating that a sentence is more than a raw number; it is a number resulting from the exercise of the district court's discretion within the confines of a dictated range. Therefore, the Supreme Court affirmed the judgment of the Court of Appeals and the district court. View "State v. Lamia-Beck" on Justia Law

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The defendant, John R. Cantu, was charged with multiple counts including felony stalking, violation of protection from stalking orders, criminal damage to property, criminal trespass, and felony criminal threat. During his trial, Cantu testified on his own behalf as the sole defense witness. However, during cross-examination, the judge removed Cantu from the stand for being uncooperative and, at the prosecutor's request, struck his entire testimony from the record. Cantu was subsequently convicted on several counts and appealed, arguing that the district court's decision to strike his entire testimony from the record deprived him of his constitutional right to testify, which was structural error requiring automatic reversal.The Court of Appeals agreed that the district court erred in ordering Cantu's testimony stricken from the record and that this error denied Cantu the constitutional right to testify. However, the panel held that the error was not structural, but could be analyzed using the harmless error standard. The panel concluded that the error was harmless and affirmed the convictions.The Supreme Court of the State of Kansas disagreed with the Court of Appeals' conclusion. The Supreme Court held that the complete and improper denial of a criminal defendant's constitutional right to testify is structural error. The court reasoned that the right to testify is a fundamental right grounded in multiple provisions of the United States Constitution. The court further explained that structural errors are defects affecting the fundamental fairness of the trial's mechanism, preventing the trial court from serving its basic function of determining guilt or innocence and depriving defendants of basic due process protections required in criminal proceedings. The court concluded that the complete and wrongful denial of a defendant's constitutional right to testify by improperly removing a defendant from the stand and striking the defendant's entire testimony is structural error because it renders the criminal trial fundamentally unfair, regardless of whether the outcome of the trial would have been different had the defendant been permitted to testify and his or her testimony been left intact. Therefore, the Supreme Court reversed Cantu's convictions and remanded for a new trial. View "State v. Cantu" on Justia Law

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The case involves a juvenile, J.L.J., who was charged with first-degree felony murder and several other offenses after he opened fire on a car, killing a 12-year-old boy. J.L.J. was certified for adult prosecution and testified that he was acting in self-defense. The jury rejected his self-defense claim and convicted him on all charges.The case was previously heard in the Leavenworth District Court where J.L.J. was convicted. On appeal, J.L.J. raised several claims of error, including prosecutorial errors and the argument that the State unconstitutionally pitted his right to prepare for his defense against his right to testify at trial.The Supreme Court of the State of Kansas affirmed the lower court's decision. The court found that while the prosecutor erred by asking potential jurors if they would do their "job" and convict J.L.J., this error was harmless and did not affect the jury's verdict. The court also disagreed with J.L.J.'s argument that the prosecutor misstated the law on self-defense during closing argument. Furthermore, the court found that the State's impeachment of J.L.J. did not violate the unconstitutional-conditions doctrine. Lastly, the court declined to invoke an exception to the general preservation rule to address J.L.J.'s argument that the adult certification process violates his constitutional rights. View "State v. J.L.J." on Justia Law

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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

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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