Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the order of the district court denying Defendant's postsentencing motion to withdraw his plea of no contest to first-degree felony murder, holding that Defendant did not meet his burden to establish that the district court abused its discretion.In his motion, Defendant argued that he did not fairly and knowingly enter the plea because his attorney provided ineffective representation by withholding discovery materials and not giving him sufficient time to review the plea agreement. The district court denied the motion, concluding that Defendant failed to show a manifest injustice. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant's plea withdrawal motion. View "State v. Shields" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to withdraw plea, which Defendant filed approximately seven years after he was convicted, holding that the district court did not err in denying Defendant's motion without an evidentiary hearing.Defendant was convicted of first-degree murder on a plea contest. Roughly seven years after he was convicted, Defendant filed his motion to withdraw plea. The district court ruled that the motion was untimely and that Defendant had failed to make an affirmative showing of excusable neglect to extend the deadline. The Supreme Court affirmed, holding that Defendant failed to establish excusable neglect for the delayed filing. View "State v. Smith" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and aggravated robbery and his resulting sentences, holding that there was no reversible error.Defendant was found guilty by a jury of committing first-degree premeditated murder and aggravated robbery when he was fifteen years old. Defendant was sentenced life imprisonment for the murder conviction and a consecutive sixty-one months' term of imprisonment for the robbery conviction. The Supreme Court affirmed, holding (1) the district court did not err by not giving an instruction on voluntary manslaughter-heat of passion; (2) Defendant failed to show that the prosecutor erred; and (3) Defendant's sentence did not violate the Eighth Amendment's prohibition of cruel and unusual punishment under the principles announced in Miller v. Alabama, 567 U.S. 460 (2012). View "State v. Gulley" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder, aggravated battery, and criminal possession of a firearm, holding that there was no prejudicial error in the proceedings below.After he was convicted, Defendant filed a post trial motion alleging that his trial counsel was ineffective by coercing him and his witnesses to change their testimony about the events leading to the murder and by disregarding the firearm expert's testimony regarding the functionality of the victim's gun. The Supreme Court affirmed, holding that defense counsel neither disregarded the expert's testimony nor coerced Defendant or his witness to change their testimony. View "State v. Evans" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion to correct an illegal sentence, holding that there was no error in the proceedings below.Appellant was convicted of criminal solicitation to commit first-degree murder and first-degree murder and sentenced to life in prison without the possibility of parole for forty years. Appellant later filed a motion to correct an illegal sentence under Kan. Stat. Ann. 22-3504, arguing that his hard forty sentence was illegal. The district court summarily denied the motion. The Supreme Court affirmed, holding (1) as to Appellant's first claim of error, the sentence the court orally imposed at the sentencing hearing conformed to the appropriate statutory language, and Appellant was serving a legal sentence; and (2) as to Appellant's second and third claims, section 22-3504 was an improper vehicle to challenge the trial court's alleged procedural errors. View "State v. Juiliano" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating Defendant's sentence imposed following his plea of guilty to aggravated escape from custody, holding that the court of appeals erred in vacating the reclassification of Defendant's criminal history.After a hearing, the sentencing court sentenced Defendant to a prison term of forty months, with twenty-four months' postrelease supervision. Defendant filed a motion to correct an illegal sentence, arguing that the sentencing court illegally reclassified his 2005 conviction and sentence from nonperson to person. The trial court denied the motion. The court of appeals vacated the reclassification of Defendant's criminal history. The Supreme Court reversed, holding that under the Kansas Sentencing Guidelines Act, Kan. Stat. Ann. 21-6801 et seq., all prior convictions are to be classified as person or nonperson as of the time the new crime is committed. View "State v. Terrell" on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's motion for postconviction discovery, holding that Defendant failed to demonstrate that the district court's ruling constituted an abuse of discretion.Defendant was convicted and sentenced for first-degree felony murder and other crimes. Defendant later filed a motion for postconviction discovery under State v. Mundo-Parra, 462 P.3d 1211 (Kan. 2020), arguing that postconviction discovery was necessary to protect substantial rights. The Supreme Court affirmed, holding that, assuming without deciding that Mundo-Parra defines a defendant's legal right to postconviction discovery, the district court did not base its decision on an erroneous legal conclusion. View "State v. Butler" on Justia Law

The Supreme Court reversed the panel of the court of appeals that applied the 2018 amendments to Kan. Stat. Ann. 8-1567, the driving under the influence (DUI) statute, to Defendant, who committed a DUI before, but was sentenced after, the amendments came into effect, holding that the court of appeals erred.The Supreme Court clarified the general rule established in State v. Reese, 333 P.3d 149 (Kan. 2014), that courts should apply the DUI sentencing provisions in effect at the time of sentencing but holding that a sentencing court should apply the version of section 8-1567 in effect at the time of sentencing unless the Legislature amended the statutory provisions after the offense was committed and that amendment increases the defendant's penalty. The Court remanded the matter to the district court for resentencing under the sentencing provisions in effect when Defendant committed the DUI, holding that applying the 2018 amendments to Defendant at sentencing would increase his punishment in violation of the Ex Post Facto Clause. View "State v. Patton" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of first-degree felony murder and one count each of intentional second-degree murder and attempted intentional second-degree murder, holding that Defendant was not entitled to relief on his claims on appeal.On appeal, Defendant argued that the trial court erred in instructing the jury on voluntary manslaughter as an additional underlying felony of felony murder and that the State presented insufficient evidence to support his convictions. The Supreme Court affirmed, holding (1) there was no instructional error; and (2) the evidence was sufficient to support Defendant's convictions. View "State v. Roberts" on Justia Law

The Supreme Court reversed the rulings of the district court and court of appeals that the district court had the authority to revoke Defendant's probation, holding that Defendant's probation revocation must be set aside because the district court lacked authority to require him to serve his prison sentence.At issue on appeal was whether the thirty-day extension allowed under Kan. Stat. Ann. 22-3716(e) for a court to initiate certain actions to revoke a criminal defendant's probation applies when, as happened in this case, an intensive supervision officer issues an arrest and detain notice within thirty days of probation expiring. The court of appeals concluded that the district court had the authority to impose sanctions for Defendant's probation violation. The Supreme Court reversed, holding that the district court acted without authority in revoking Defendant's probation and sending him to prison. View "State v. Darkis" on Justia Law