Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming Defendant’s convictions for possession of marijuana with intent to sell and failure to pay the Kansas drug tax stamp, holding that there was reasonable suspicion to support the seizure of an intercepted UPS package.Defendant filed a motion to suppress the evidence resulting from the detention of the intercepted UPS package, arguing that law enforcement seized the package in violation of his constitutional rights because reasonable suspicion was lacking where there was nothing unusual about the package’s appearance. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the government had reasonable suspicion to seize the package; and (2) the court of appeals did not err when it held that Defendant had not preserved his argument that the authorities detained his package for an unreasonable length of time. View "State v. Ton" on Justia Law

The Supreme Court affirmed Defendant’s convictions for first-degree murder, two counts of aggravated burglary, and other crimes, holding that none of Defendant’s contentions on appeal warranted reversal.Specifically, the Supreme Court held (1) there was sufficient evidence to support Defendant’s convictions for aggravated burglary, first-degree murder, and theft; (2) the district court did not abuse its discretion when it found that no juror misconduct occurred; and (3) the district court did not abuse its discretion when it found that it could retrospectively determine whether Defendant was competent to stand trial. View "State v. Jenkins" on Justia Law

Defendant had a reasonable expectation of privacy in Alexis Tracy’s apartment at the time the apartment was searched by law enforcement officers, and therefore, Defendant had standing to challenge the search.Law enforcement officers failed to find Defendant in a search of Tracy’s apartment but did find Defendant’s safe, which contained methamphetamine. The State charged Defendant with possession with intent to distribute methamphetamine and no drug tax stamp. Defendant moved to suppress the evidence, arguing that the search exceeded the scope of Tracy’s consent. The district court suppressed the evidence. The court of appeals reversed, concluding that Defendant lacked standing to challenge the search because he was not present at the time of the search and therefore was not a current guest at Tracy’s apartment. The Supreme Court remanded to the court of appeals for further proceedings, holding that Defendant was a welcomed social guest at Tracy’s apartment and did not lose any reasonable expectation of privacy the moment he left the apartment. View "State v. Dannebohm" on Justia Law

Defendant Matthew Wilson proximately caused Michael Lowery’s death by attacking those in the apartment, including Joel Solano, leading to Solano’s foreseeable defensive response of accidentally killing Lowery.After Wilson broke into an apartment and began shooting the occupants, Solano grabbed a gun and hid in his room. Lowery fled from Wilson into the room occupied by Solano, who mistook Lowery for the shooter and shot him dead. Wilson pled no contest to premeditated murder for Lowery’s death. Wilson later filed a pro se motion to withdraw his no contest pleas, arguing that there was an insufficient basis to support the elements of premeditated murder because he did not actually kill Lowery. The district court summarily denied the motion. The Supreme Court affirmed, holding that a factual basis supported Wilson’s plea because he did not contest the element of premeditation and his attack proximately caused Lowery’s death. View "State v. Wilson" on Justia Law

In this case involving the manifest justice factors in Kan. Stat. Ann. 60-1507, both pre- and post-amendment, the Supreme Court held that, based on the record before it, it could not be determined whether Defendant established manifest injustice.On year after a statutory deadline, Defendant filed a section 60-1507 motion asking the district court to apply the manifest injustice exception in section 60-1507(f), which allows consideration of section 60-1507 motions even if filed late. The district court denied the motion. While Defendant’s appeal was pending, the Legislature amended the statute and changed the manifest injustice factors. The Supreme Court remanded the case, holding (1) the amendments to section 60-1507 do not apply retroactively, and the preamendment factors govern Defendant’s appeal; and (2) although the district court applied the preamendment factors, the court’s findings of fact are insufficient for appellate review. View "White v. State" on Justia Law

The law enforcement officer in this case conducted a constitutional search under the United States Supreme Court’s holding in Arizona v. Gant, 556 U.S. 332 (2009), relating to a search-incident-to-lawful-arrest exception in a vehicle context.Defendant sold methamphetamine to a confidential informant (CI). The CI paid for the methamphetamine with $220 cash provided by law enforcement officers who had recorded each bill’s serial number. Defendant entered a nearby apartment and then got in the passenger seat of a car and left. A law enforcement officer pulled over the car. Another officer formally arrested Defendant and searched the car, finding $200 of the recorded money. Defendant moved to suppress the evidence seized in the car search, arguing that the officer conducted an illegal, warrantless search without probable cause or a reasonable basis to believe the money at issue would be in the car rather than the apartment. The district court denied the motion. The court of appeals appealed, concluding that the search fell within the automobile and search-incident-to-lawful-arrest exceptions to the warrant requirement. The Supreme Court affirmed, holding that, under Gant, the car was validly searched as a search incident to a lawful arrest. View "State v. Torres" on Justia Law

The Supreme Court affirmed Defendant’s conviction for felony murder, holding that sufficient evidence supported the conviction even where the State charged Defendant as the killer but the trial evidence established that his cousin fired the fatal shot.The Court held (1) because the trial record provided sufficient evidence that Defendant participated in the crime of an aggravated burglary during which an individual was killed, and because the issue of whether Defendant was the triggerman bore no relevance to that determination, a rational factfinder could have found Defendant guilty of felony murder beyond a reasonable doubt; (2) the felony-murder elements instruction was not overly broad; and (3) any alleged error in the felony-murder elements instruction was harmless. View "State v. Robinson" on Justia Law

The Supreme Court affirmed Defendant’s convictions of aggravated burglary and first-degree felony murder.Defendant was charged with aggravated burglary and first-degree felony murder. A jury convicted Defendant of aggravated burglary but failed to reach a verdict on the felony-murder charge. The jury hung after a second trial. A third jury convicted Defendant of felony murder.The Supreme Court affirmed, holding (1) the district judge erred by communicating with jurors, outside Defendant’s presence, during the third trial about notes found in the jury room, but there was no reasonable possibility that the error affected the verdict; (2) the district judge erred by shredding notes found in the jury room without first showing the notes to Defendant and his attorney, but Defendant did not show reversible error; (3) the district judge did not err during the third trial by admitting evidence of Defendant’s interview with law enforcement officers because Defendant voluntarily waived his Miranda rights; (4) the district judge did not err in its response to a jury question asked during the first trial; and (5) reversal was not required under the cumulative error doctrine. View "State v. Walker" on Justia Law

The district court properly suppressed drug-related evidence discovered in a vehicle search following a traffic stop because the officer improperly prolonged the traffic stop.The district court found the initial traffic stop was lawful and that the stop ended when the officer gave Defendant a warning citation and his documents and told him he was free to leave. The court concluded that a consensual encounter then occurred but ended when the officer told Defendant to sit down inside the police car and that there was no probable cause to justify the vehicle search. The Supreme Court affirmed, holding that the officer did not have reasonable suspicion to detain Defendant after the traffic stop, and therefore, the State did not meet its burden to show that the challenged seizure was lawful. View "State v. Lowery" on Justia Law

A law enforcement officer’s detailed questions into a driver’s travel plans measurably extended the stop’s duration and were not justified by any reasonable suspicion of or probable cause to believe there was other criminal activity.Defendant moved to suppress the traffic stop evidence, arguing that the officer measurably extended the stop by asking travel plan questions before processing the driver’s license and warrant information. The court granted the motion to suppress, concluding that the officer measurably extended the stop with travel plan questioning unrelated to the traffic violation and that the officer lacked a reasonable suspicion that other criminal activity was occurring to justify the delay. The court of appeals reversed, holding that no constitutional violation occurred because travel plan questions are always within a stop’s scope. The Supreme Court reversed, holding that because there was no colorable, independent justification for the portions of the detention attributable solely to unrelated inquiries into Defendant’s travel plans, this extended detention violated the Fourth Amendment. View "State v. Jimenez" on Justia Law