Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of felony murder, aggravated assault, felony discharge of a firearm, and aggravated endangering of a child, holding that no reversible error occurred.Defendant was convicted of felony murder based on the underlying inherently dangerous felonies of criminal discharge of a firearm at an occupied dwelling and aggravated endangering of a child. The Supreme Court affirmed Defendant's conviction and sentence for felony murder, holding (1) the underlying felonies supported Defendant's convictions and sentences; and (2) Defendant's claims that the trial judge erred in instructing the jury lacked merit. View "State v. Pattillo" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree premeditated murder, aggravated burglary, and arson, holding that no error required reversal.Specifically, the Supreme Court held (1) the district court judge did not err by refusing to give a voluntary intoxication instruction or a voluntary manslaughter instruction; (2) Defendant failed to preserve for appeal his argument that the district judge erred in admitting a videotaped interrogation of him into evidence because law enforcement agents repeatedly challenged his honesty and truthfulness during that interrogation; and (3) the district judge did not err in refusing to give a cautionary instruction on informant testimony. View "State v. Green" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree premeditated murder, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) even if a challenged remark by the prosecutor constituted prosecutorial error, there was no possibility that it contributed to the verdict; (2) the district court did not err in admitting cell tower maps and accompanying testimony; (3) the district court did not commit clear error in failing sua sponte to instruct the jury on intentional second-degree murder as a lesser included offense of premeditated first-degree murder; and (4) the district court's failure to give any lesser included instructions did not violate Defendant's due process rights. View "State v. Timley" on Justia Law

The Supreme Court affirmed the decision of the Court of Appeals reversing the judgment of the district court denying Defendant's motion to suppress drug-related evidence, holding that that the Court of Appeals correctly denied the motion to suppress.Defendant was charged with possession of methamphetamine and possessing drug paraphernalia. Defendant filed a motion to suppress, arguing that she was unlawfully detained. In response, the State argued that the attenuation doctrine legitimized the seizure. The Court of Appeals reversed, holding that the investigatory detention of Defendant exceeded the scope of the initial welfare check. The Supreme Court affirmed, holding (1) where the police officer had no reasonable suspicion that Defendant was committing, had committed, or was about to commit a crime the officer's conduct constituted an unlawful seizure and consequent search; and (2) the facts of this case rendered application of the attenuation doctrine inappropriate. View "State v. Ellis" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree premeditated murder and other crimes, holding that the prosecutor did not err during closing arguments by saying, "The defense has speculated about other peoples [sic] motives, but the State has actually presented evidence."On appeal, Defendant argued that the prosecutor impermissibly shifted the burden of proof from the State to the defense and infringed on his constitutional protections against compulsory self-incrimination. The Supreme Court disagreed, holding that the prosecutor's comments did not offend Defendant's constitutional right to a fair trial and did not fall outside the wide latitude afforded prosecutors to conduct the State's case. View "State v. Martinez" on Justia Law

The Supreme Court reversed Defendant's conviction for aggravated battery but affirmed his convictions for abuse of a child and aggravated endangering of a child, holding that the cumulative effect of certain errors required reversal of the aggravated battery conviction.Specifically, the Supreme Court held (1) the district court erred by giving jury instructions that allowed the jury to convict Defendant of aggravated battery if it found that Defendant intended the conduct but not the harm; (2) during closing arguments, the prosecutor erred by telling jurors to acquit only if the jurors thought it was acceptable to inflict injuries on their children; and (3) the two errors when considered together were not harmless as to the aggravated battery conviction. Further, the Supreme Court held the district court erred by scoring a previous out-of-state conviction from Virginia for domestic assault and battery as a person crime. View "State v. Thomas" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that Defendant did not establish that he was prejudiced by his counsel's performance, holding that Defendant met his burden of showing that there was a reasonable probability that, but for his trial counsel's deficient performance, the result of his trial would have been different.Defendant was convicted of second-degree murder. The court of appeals affirmed. Defendant later moved to have his conviction set aside, arguing that his appointed trial counsel provided ineffective assistance by failing to admit into evidence a recording of a 911 call in which the caller identified someone other than Defendant as the person who killed the victim. The district court denied relief, and the court of appeals affirmed. The Supreme Court reversed, holding (1) counsel's failure to introduce the 911 call fell below an objective standard for reasonably effective representation; and (2) Defendant was prejudiced by his counsel's deficient performance. View "Balbirnie v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court judge denying Defendant's motion for a new trial on the basis of DNA testing results, holding that the district judge did not abuse her discretion by concluding that there was no "reasonable probability" the DNA results would have changed the original trial's outcome.Defendant was convicted of first-degree murder, conspiracy to possess with intent to sell hallucinogenic drugs, and aggravated robbery. Approximately a dozen years later, Defendant filed a request for DNA testing on some items found at the crime scene. The district judge granted the request. Defendant filed a motion to set aside his conviction or grant him a new trial in light of the DNA test results. The district judge denied the motion, concluding that the new DNA evidence was "not reasonably probable to lead to a jury reaching a different result." The Supreme Court affirmed, holding that the district judge did not abuse her discretion in denying relief. View "State v. Edwards" on Justia Law

The Supreme Court affirmed the decision of the trial court denying Defendant's pro se motion styled as a "Motion to Set Aside a Void Judgment under Due Process of Law and K.S.A. 22-3210," holding that the trial court correctly analyzed the motion as a motion to withdraw plea under Kan. Stat. Ann. 22-3210 and did not err in denying the motion as untimely.In 2000, Defendant pleaded guilty to premeditated first-degree murder and other crimes. In 2017, Defendant filed the motion that was the subject of this appeal. The trial court construed Defendant's motion as one to withdraw his plea under section 22-3210 and denied it as untimely. Defendant appealed, arguing that the trial court erred in analyzing his motion as one to withdraw his plea instead of analyzing it as a motion to void his convictions and sentences and that he was denied due process during the plea process. The Supreme Court affirmed, holding (1) the trial court correctly analyzed the motion as one to withdraw plea; and (2) where Defendant neither asserted nor demonstrated any grounds of excusable neglect, the motion was procedurally barred. View "State v. Hill" on Justia Law

The Supreme Court affirmed Defendant's convictions of possession of marijuana and cocaine, holding that the district court did not err in allowing Defendant to exercise her constitutional right of self-representation where the record did not establish that Defendant suffered from a severe mental illness.On appeal, Defendant argued that the district court judge used the incorrect standard to determine whether she was competent to represent herself. The court of appeals affirmed. The Supreme Court affirmed, holding that, without an indication that Defendant suffered from a severe mental illness, there was no basis to conclude that the district court judge abused his discretion when he allowed Defendant to waive her right to counsel and represent herself at trial. View "State v. Burden" on Justia Law