Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of attempted capital murder, aggravated robbery, and other offenses, holding that there was no error during Defendant's trial.Specifically, the Supreme Court held (1) there was sufficient evidence presented by the State to support Defendant's convictions; (2) Defendant failed to designate a sufficient record to support his claim that the district court erred when it admitted the contents of his cell phone; (3) the district court did not err when it admitted Defendant's jail phone calls; (4) the district court properly admitted Kan. Stat. Ann. 60-455 prior crimes evidence; and (5) the district court properly admitted two timelines as evidence. View "State v. Meggerson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of two counts of aggravated robbery, holding that the court of appeals did not err in holding that the convictions would not result in a subsequent prosecution and that Defendant was not twice put in jeopardy.Defendant took the property of three individuals in one incident. Defendant was convicted of two counts of aggravated robbery and one count of theft, each count relating to a different victim. On appeal, Defendant argued that the State divided one criminal offense into three crimes in violation of double jeopardy protections. The court of appeals reversed Defendant's theft conviction and otherwise affirmed. The Supreme Court affirmed, holding (1) the charges arose from unitary conduct; (2) the State did not violate double jeopardy protection by prosecuting Defendant a second time for aggravated robbery after his theft conviction had been affirmed; and (3) Defendant's aggravated robbery convictions were not multiplicitous. View "State v. Dale" on Justia Law

The Supreme Court reversed the decision of the court of appeals panel that used a harmless error analysis to save a district court's denial of Defendant's motion to withdraw his plea even though the panel concluded that the court applied the wrong legal standard, holding the court of appeals erred in engaging in a harmless error analysis under the circumstances.Defendant pleaded no contest to robbery and aggravated assault. Before sentencing, Defendant filed a pro se motion to withdraw his plea, asserting ineffective assistance of counsel. The district court denied the motion. The panel concluded that the district court erred in using the Strickland test rather than the "lackluster advocacy" standard specified in State v. Aguilar, 231 P.3d 563 (Kan. 2010) but that the error was harmless. The Supreme Court reversed, holding that the analysis of the court of appeals was incorrect. View "State v. Herring" on Justia Law

The Supreme Court held that, on judicial review under Kan. Stat. Ann. 8-1020(p) of a hearing officer's order suspending a driver's license, a court may consider any constitutional issue, including the lawfulness of the law enforcement encounter, and that, under section 8-1020(o)-(q), a court may set aside a driver's license suspension order if the driver meets the burden of establishing that the encounter was unlawful.Defendant was arrested for driving under the influence. When Defendant refused to provide a breath sample his driver's license was suspended. A district court judge set aside the suspension based on his determination that the law enforcement encounter was unlawful. The court of appeals affirmed. The Supreme Court affirmed, holding that the stop was unlawful and violated Defendant's constitutional rights, and therefore, the district court did not err in setting aside the suspension of Defendant's driver's license. View "Jarvis v. Kansas Department of Revenue" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder and battery, holding that there was no reversible error on the part of the district court.After a jury trial, Defendant was found guilty of first-degree murder and battery. The district court imposed a hard fifty sentence for the murder conviction and a concurrent six-month sentence for the battery conviction. The Supreme Court affirmed, holding (1) Defendant's challenges to certain jury instructions were unavailing; (2) several statements made by the prosecutor challenged by Defendant on appeal fell within the broad discretion afforded prosecutors; (3) the trial court did not abuse its discretion in admitting certain evidence; and (4) there was no sentencing error. View "State v. Willis" on Justia Law

The Supreme Court affirmed the decision of the district court summarily denying Defendant's postsentence motion to modify sentence, holding that no legal avenue existed for the relief requested by Defendant.Defendant was convicted of premeditated first-degree murder and three counts of aggravated assault. The district court sentenced Defendant to a hard forty life sentence on the murder charge and added thirteen additional months in prison for the aggravated assault charges. On appeal, the Supreme Court remanded for resentencing on the murder charge. On remand, Defendant was again sentenced to a hard forty life time for first-degree murder. The Supreme Court affirmed. Defendant later filed a pro se motion seeking to have his hard forty life sentence modified to require no mandatory term of imprisonment, arguing that his sentence violated the Sixth Amendment because the trial judge and not a jury made the factual findings necessary for sentence enhancement. The district judge denied the motion. The Supreme Court affirmed, holding that Alleyne v. United States, 570 U.S. 99 (2013), and State v. Soto, 322 P.3d 334 (2014), did not operate retroactively to provide a remedy in this case and that Kan. Stat. Ann. 21-6628(c) did not apply. View "State v. Coleman" on Justia Law

The Supreme Court reversed Defendant's conviction of first-degree premeditated murder, holding that the district court erred in not instructing the jury on self-defense and that the error was reversible.At the close of the evidence, Defendant requested jury instructions on self-defense and involuntary manslaughter. The court declined to give the requested instructions, finding that the evidence failed to support either instruction. On appeal, Defendant argued that the district court committed reversible error when it refused to give his requested instructions. The Supreme Court reversed, holding that Defendant's testimony sufficed to make a self-defense instruction factually appropriate and that the district court's error in refusing to give the instruction was reversible. View "State v. Keyes" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing Defendant's convictions on two counts of aggravated criminal sodomy, holding that Defendant received deficient representation pretrial and at trial and that Defendant was prejudiced as a result.After Defendant's conviction was affirmed on direct appeal he filed a Kan. Stat. Ann. 60-1507 motion alleging that trial and appellate counsel provided ineffective assistance. The court of appeals concluded that Defendant's counsel had not met the constitutional standard for effective assistance of trial or appellate counsel and that Defendant was prejudiced as a result. The Supreme Court affirmed, holding that trial counsel's decision to drop a pretrial challenge to the admissibility of Defendant's incriminating statements and counsel's failure to object to certain evidence being admitted at trial constituted ineffective assistance of counsel. View "Khalil-Alsalaami v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court ordering Defendant to register as a violent offender under the Kansas Offender Registration Act (KORA), Kan. Stat. Ann. 22-4901 et seq., holding that the district court's notice to Defendant concerning his obligation to register did not violate Defendant's right to due process.Defendant was convicted and sentenced for aggravated burglary. The district court ordered Defendant to register as a violent offender under KORA. On appeal, Defendant argued that the district court's failure to notify him of his registration obligation at the time of his plea and conviction violated his right to procedural due process under the Fourteenth Amendment. The Supreme Court disagreed, holding that the notice provided to Defendant was constitutionally sound and that Defendant was not deprived of his opportunity to be heard. View "State v. Juarez" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing Defendant's conviction of one count of criminal threat under Kan. Stat. Ann. 21-5415(a)(1), holding that there was no basis for this Court to discern whether the jury concluded the State had proved beyond a reasonable doubt that Defendant committed criminal threat intentionally.On appeal, the court of appeals concluded that the trial court erred by rejecting defense counsel's proposed jury instruction on workplace defense. The State sought review. While review was pending, the Supreme Court held in State v. Johnson, 450 P.3d 790 (Kan. 2019), that the provision in section 21-5415(a)(1) allowing conviction if a threat of violence was made in reckless disregard for causing fear was unconstitutionally overbroad. The Supreme Court affirmed the court of appeals' judgment as right for the wrong reason, holding that, based on Johnson, Defendant's conviction cannot stand. View "State v. Lindemuth" on Justia Law