Justia Criminal Law Opinion Summaries

The Supreme Court held that the lower courts erred in concluding that the traffic stop in this case was impermissibly extended.The district court suppressed from evidence thirty-eight pounds of marijuana seized after a traffic stop, finding that the stop was unconstitutionally extended. The court of appeals affirmed. The Supreme Court disagreed with the lower courts, holding (1) discrepancies between the driver’s statements and the vehicle-related documents justified the deputy’s progressive questioning; (2) the questioning occurred simultaneously with the deputy’s appropriate steps in processing the traffic stop; and (3) the circumstances provided the officer reasonable suspicion to extend the detention and for a drug dog sniff. View "State v. Schooler" on Justia Law

At issue was whether a criminal defendant’s claim of actual innocence may excuse procedural defaults that would otherwise bar litigation of motions filed under Kan. Stat. Ann. 60-1507.The Supreme Court reversed the decision of the court of appeals affirming the district court’s summary denial of Defendant’s Kan. Stat. Ann. 60-1507 motion and remanded to the district court for an evidentiary hearing on his gateway claim of actual innocence. The motion underlying this appeal was untimely and successive, and to avoid the resulting procedural bars, Defendant argued manifest injustice based on his claim of actual innocence. The Supreme Court held that Defendant’s assertion of actual innocence entitled him to an evidentiary hearing to determine its credibility. Specifically, the Court held that an evidentiary hearing was required to determine whether Defendant’s assertion established manifest injustice or exceptional circumstances sufficient to require the district court to address the merits of his ineffective assistance of counsel claim. View "Beauclair v. State" on Justia Law

The Supreme Court reversed the court of appeals ruling on Defendant’s motion for a new trial in this criminal case and affirmed Defendant’s conviction for felony burglary and the district court’s denial of Defendant’s motion for a new trial.The court of appeals affirmed Defendant’s conviction but reversed on the question of the effectiveness of Defendant’s counsel, particularly with respect to a conflict of interest when arguing Defendant’s pro se motion for change of counsel prior to sentencing. Because Defendant’s motion for new trial was filed out of time, the court of appeals treated it as a motion under Kan. Stat. Ann. 60-1507. The court of appeals remanded for a hearing, complete with new appointed counsel. The Supreme Court reversed, holding that by granting Defendant a full hearing with new counsel, the court of appeals erroneously provided Defendant with more procedural rights than he may have received if he had filed his motion on time or had filed a true section 60-1507 motion. View "State v. Jarmon" on Justia Law

The Supreme Court affirmed Defendant’s convictions for capital murder and aggravated kidnapping but, as to Defendant’s death sentence, the Court remanded the limited question on intellectual disability to the district court for further proceedings.On appeal, Defendant argued (1) numerous errors occurred during his trial’s guilt phase; and (2) evidence from his 2009 penalty-phase proceedings demonstrated that he was intellectually disabled and that the district court erred when it found insufficient reason to believe that Defendant was intellectually disabled. The Supreme Court remanded the case, holding (1) no reversible error occurred during the trial’s guilt phase; but (2) as to Defendant’s death sentence, new rules for conducting criminal prosecutions have been enacted since Defendant’s trial, and therefore, the best interests of justice require reversing the district court’s reason-to-believe determination and remanding for reconsideration based on current constitutional parameters. View "State v. Thurber" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the decision of the district court, which ordered a reduced term of ten years of postrelease supervision after finding that a sentence of lifetime postrelease supervision would be unconstitutional as applied to Defendant. In reversing, the court of appeals directed the district court to impose lifetime postrelease supervision. The Supreme Court reversed, holding that the district court made a legal error in its analysis and that the court of appeals erred when it did not remand the case for the purpose of using the proper legal standard to consider whether lifetime postrelease supervision was unconstitutional as applied to Defendant. View "State v. Riffe" on Justia Law

The Supreme Court reversed the portion of the court of appeals decision affirming the district court’s order of restitution because neither the district court nor the court of appeals had the advantage of the decision in State v. Arnett, 413 P.3d 787 (Kan. 2018), when calculating or considering the restitution order here.Defendant pleaded no contest to the residential burglary of Ryan Platt’s home. The trial court denied Defendant’s motion to limit restitution to $250 in damage caused to the screen door in the residential burglary and ordered the restitution requested by the State. The Supreme Court reversed the portion of the court of appeals decision upholding the order that Defendant pay $680 for items removed from Platt’s home and vehicle and remanded for a new hearing on restitution, directing the district court to reconsider its calculation of restitution under the standard adopted in Arnett. View "State v. Futrell" on Justia Law

A defendant may not assert self-defense if that defendant is already otherwise committing a forcible felony when he or she commits a separate act of violence.The Supreme Court affirmed Defendant’s conviction of criminal discharge of a firearm into a vehicle under a theory of aiding and abetting, holding that there was no basis for reversal. The primary issue on appeal was whether the district court erred in denying Defendant’s request for an instruction on self-defense. The court of appeals held that the instruction was legally inappropriate in this case because Defendant was charged with a violent felony, which prevented him from asserting a theory of self-defense. The Supreme Court disagreed, holding that under the new rule articulated above, the requested instruction was legally appropriate. But because the evidence was not factually appropriate, the district court properly denied Defendant’s request for an instruction on self-defense. The Supreme Court further held that Defendant’s remaining allegations of error were unavailing. View "State v. Barlett" on Justia Law

The district court erred in this case by denying Defendant’s petition for DNA testing of hairs found at the crime scene.Defendant was convicted of kidnapping, rape, aggravated robbery, and aggravated intimidation of a witness or victim. Defendant later filed a pro se petition for postconviction DNA testing under Kan. Stat. Ann. 21-2512 asking that collected by previously untested hairs found at the crime scene be tested against the DNA profile of the victim’s boyfriend. In denying the petition, the district court relied on the legal standard from State v. Lackey, 208 P.3d 793 (Kan. 2009)(Lackey I), which had been overruled by State v. Lackey, 286 P.3d 859 (Kan. 2012)(Lackey II), before the district court ruling. The court of appeals affirmed, ruling that while the district court erred in relying on Lackey I, the decision to deny should still be affirmed. The Supreme Court reversed and remanded the case for further proceedings, holding that the lower courts erred because the testing of hair from the crime scene may have produced exculpatory evidence that was “noncumulative” as required by the statute. View "State v. George" on Justia Law

The Supreme Court affirmed the denial of Appellant’s pro se motion to set aside a “void judgment," holding that Appellant’s counsel’s urging that the court treat Appellant’s motion as one under Kan. Stat. Ann. 22-3210 to withdraw Appellant’s no contest plea accepted by the court nineteen years earlier qualified as invited error.Because Appellant failed to allege the required excusable neglect under section 22-3210’s provision allowing late motions for plea withdrawal, the district court denied the motion on the grounds that it was untimely. On appeal, Appellant argued that the district court should have construed his motion as one under Kan. Stat. Ann. 60-1507 and allowed the untimely filing to prevent manifest injustice. The Supreme Court affirmed, holding (1) the invited error doctrine applied because Appellant’s counsel twice invited the district court to treat the pleading as a motion to withdraw plea; and (2) the district court properly found that the motion was untimely. View "State v. Parks" on Justia Law

The Supreme Court affirmed Defendant’s convictions for felony murder, rape, and aggravated burglary arising from an attack on 100-year-old M.S. in her home.On appeal, Appellant argued, among other things, that there was insufficient evidence to support the felony murder conviction because M.S.’s death twenty-one days after the attack did not occur within the res gestate of the underlying felony of rape and because there was no direct causal connection between the rape and M.S.’s death. The Supreme Court held (1) the record supported the jury’s decision that the act causing M.S.’s death occurred within the res gestate of the underlying felony of rape, and the evidence was sufficient to support causation; (2) there was sufficient evidence to support the aggravated burglary conviction; (3) an erroneous statement by the prosecutor during closing argument was harmless; and (4) the judge did not err when he refused to give a proposed race-switching instruction. View "State v. Nesbitt" on Justia Law