Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree murder and two counts of interference with a law enforcement officer and his controlling hard fifty sentence, holding that the district court's evidentiary rulings were not in error and that cumulative error did not deny him a fair trial.On appeal, Defendant asserted that the district court repeatedly erred by admitting evidence in violation of Kan. Stat. Ann. 60-455 and by admitting hearsay evidence. The Supreme Court affirmed, holding (1) even assuming that the district court judge erred by either failing to properly analyze evidence under section 60-455, failing to properly exclude it, or failing to properly instruct the jury, the error would be harmless in light of the entire record; (2) Defendant's second claim of error was plainly invited by Defendant; and (3) the evidence continued to render the assumed errors in this case harmless, even when their cumulative effect was considered. View "State v. Knapp" on Justia Law

The Supreme Court dismissed for lack of jurisdiction this appeal brought approximately nineteen years after a district court adjudicated I.A. as a juvenile offender, holding that due process and procedural fairness did not require this Court to hear I.A.'s out-of-time appeal.I.A. pled guilty to two counts of reckless aggravated battery for acts he committed when he was seventeen years old. About nineteen years after his sentencing, I.A. filed a pro se request to file a direct appeal out of time, arguing that the judge had not announced his right to appeal. The court of appeals held that it did not have jurisdiction and dismissed the appeal. The Supreme Court affirmed, holding that Kansas appellate courts lack jurisdiction to hear an appeal if a juvenile offender did not follow statutory directives, and due process did not require the Court to make an exception. View "In re I.A." on Justia Law

The Supreme Court reversed in part and affirmed in part Defendant's convictions for premeditated first-degree murder, felony murder (in the alternative), two counts of aggravated kidnapping, aggravated battery, conspiracy to distribute a controlled substance, and rape, holding that the State presented insufficient evidence to support Defendant's conviction for conspiracy to distribute a controlled substance.Specifically, the Supreme Court held (1) Defendant failed to preserve an objection to the district court's limitation of cross-examination of a witness's potential charges or sentences; (2) the district court did not abuse its discretion in limiting cross-examination of another witness; (3) the prosecutor did not misstate the law during closing arguments; (4) there was no error in the jury instructions; (5) the prosecutor did not commit error by describing the proper sequence of consideration of lesser included offenses during closing arguments; (6) Defendant's conviction for conspiracy to distribute a controlled substance was unsupported by the evidence; (7) the district court properly admitted the admission of an audio recording of an individual's torture; and (8) Defendant's prior California crime was properly classified as a person felony. View "State v. Hillard" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court revoking Defendant's probation and ordering him to serve his underlying sentence, holding that the district court did not err in revoking Defendant's probation.Defendant entered into a plea agreement for failing to register as an offender. The district court sentenced him to 120 months' incarceration but granted him probation for a thirty-six-month period. In 2013, the State filed a second motion to revoke Defendant's probation, alleging several violations. The district court revoked Defendant's probation and ordered him to serve his original prison sentence. The Supreme Court reversed in part and remanded the case. On remand, the court revoked Defendant's probation and ordered him to serve his underlying sentence. The court of appeals affirmed. The Supreme Court affirmed, holding that there was no error by the district court or the court of appeals. View "State v. Dooley" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentences stemming from three murders at her home, holding that none of Defendant's allegations of error warranted reversal of her convictions.A jury convicted Defendant of three counts of felony murder with two alternative underlying felonies, aggravating kidnapping or aggravated assault, and related crimes. The Supreme Court affirmed, holding (1) the prosecutor did not misstate the law during closing arguments and made a permissible statement about credibility; (2) the district court did not by refusing to modify Instruction No. 8 to make explicit reference about witnesses who testify for the State in exchange for receiving benefits; and (3) the record was inadequate to permit meaningful appellate review of Defendant's sentencing agreement claim. View "State v. Liles" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to withdraw his plea of guilty to two counts of felony first-degree murder, holding that Defendant failed to prove manifest injustice in the circumstances of entering his guilty plea.Defendant pled guilty two two counts of felony first-degree murder, and the court sentenced him to two consecutive hard twenty-five life sentences. Defendant then filed his pro se motion seeking relief on a wide variety of grounds. The trial court denied relief. The Supreme Court affirmed, holding that any failures on the part of counsel to inform Defendant that compulsion is a defense to felony murder did not rise to the level of manifest injustice that would require a court to give him leave to withdraw his plea. View "State v. Hutto" on Justia Law

The Supreme Court affirmed the decision of the court of appeals to dismiss this appeal of a judgment of conviction, holding that the court of appeals correctly held that it lacked jurisdiction over Defendant's appeal.Defendant committed a felony while on probation for another felony conviction. The sentencing judge ordered Defendant to serve the presumptive sentence for his new conviction under the Kansas Sentencing Guidelines Act (KSGA), Kan. Stat. Ann. 21-6801 et seq., and ordered Defendant to serve his sentence consecutive to the sentence for the earlier crime. Defendant appealed, arguing that the sentencing judge should have applied Kan. Stat. Ann. 21-6819(a), which allows a judge to impose concurrent sentences if the term of imprisonment resulting from the application of Kan. Stat. Ann. 21-6606, which the judge applied in this case, would be manifestly unjust. The court of appeals dismissed the appeal. The Supreme Court affirmed, holding that the appellate court lacked jurisdiction to review the sentencing judge's decision applying section 21-6606 rather than section 21-6819(a). View "State v. Young" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's postconviction motion to compel the production of records related to his criminal case, holding that there was no basis for the discovery Appellant requested.More than a decade ago, Appellant went through criminal proceedings that led to his conviction of first-degree premeditated murder. At issue was Appellant's "pro se and barebones" postconviction motion to compel production of records related to his criminal proceedings. The district court denied the motion. The Supreme Court affirmed, holding (1) there was no support for Appellant's theory that Kan. Stat. Ann. 22-3212 and 22-3213 apply to his motion for postconviction discovery; and (2) because Appellant cited no other basis for the requested discovery, the district court properly denied his motion to compel discovery. View "State v. Marks" on Justia Law

The Supreme Court affirmed Defendant's convictions on three counts of first-degree premeditated murder, holding that Defendant was not entitled to relief on his two instructional error claims and his one prosecutorial error claim.Specifically, the Supreme Court held (1) any error committed by the trial court in failing to instruct the jury on both second-degree intentional murder and voluntary manslaughter as lesser included offenses was not reversible; (2) the prosecutor offered his personal opinion in using the rhetorical phrase "we know" during closing argument, but the error was not reversible; and (3) collectively, the one error and two assumed instructional errors did not produce the degree of prejudice necessary for reversal. View "State v. Douglas" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion to correct an illegal sentence under Kan. Stat. Ann. 22-3504 asserting that his sentence was unconstitutional, holding that the Legislature has foreclosed Appellant's ability to challenge the constitutionality of his sentence through the illegal sentence statute.Appellant was sentenced to three consecutive life sentences for multiple felonies he committed as a juvenile. Decades later, Appellant filed a pro se motion seeking relief under section 22-3504 and Kan. Stat. Ann. 60-1507. The district court denied the motion. The Supreme Court affirmed, holding that Appellant's challenges fell outside the narrow definition of an "illegal sentence" under section 22-3504, and Appellant abandoned any other claim for relief on appeal. View "State v. R.H." on Justia Law