Justia Constitutional Law Opinion Summaries

The case involves Kimberly S. Younger, who was convicted of capital murder, conspiracy to commit first-degree murder, solicitation to commit first-degree murder, and theft. Younger was implicated as the principal organizer of the murders of Alfred and Pauline Carpenter, who were killed by Michael Fowler and Rusty Frasier, both of whom testified against her. The murders occurred at the Barton County fairgrounds, and the bodies were later disposed of in Arkansas. Younger was arrested in Arkansas, where she made several incriminating statements to the police and to Fowler, which were recorded.The Barton District Court convicted Younger based on the testimonies of her co-conspirators and other evidence. Younger challenged several evidentiary rulings, including the admission of her statements to the police and the testimony of Frank Zaitshik, who testified remotely due to COVID-19 concerns. The trial court allowed Zaitshik's remote testimony, finding it necessary due to the pandemic. The court also admitted Younger's statements made during her interrogation and to Fowler, finding them voluntary and not coerced.The Kansas Supreme Court reviewed the case and affirmed the trial court's decisions in part. The court held that allowing Zaitshik to testify remotely did not violate Younger's Confrontation Clause rights, given the pandemic's circumstances. The court also found that Younger's statements to the police and Fowler were voluntary and admissible. However, the court reversed the restitution order in part, finding that the State failed to justify the amount awarded to State Farm Insurance and that the inclusion of court costs in the restitution order was illegal. The case was remanded to correct the restitution judgment. View "State v. Younger" on Justia Law

In 2015, Brennan R. Trass was charged with first-degree felony murder and criminal possession of a firearm after killing Jose Morales during a drug deal. Trass admitted to the shooting, claiming self-defense. Before trial, the district court appointed multiple attorneys for Trass due to conflicts, causing significant delays. Two weeks before the trial in 2019, the court allowed Trass' attorneys to withdraw due to a conflict and ordered Trass to represent himself with standby counsel. During the trial, Trass was removed from the courtroom for refusing to participate, and his standby counsel took over. The jury convicted Trass.The Reno District Court initially handled the case, where Trass faced multiple attorney changes and delays. Trass filed a direct appeal, and the Kansas Supreme Court remanded the case to the district court to determine the feasibility of a retrospective competency hearing. The district court found Trass competent before and during his 2019 trial. Trass raised several issues on appeal, including violations of his right to counsel, speedy trial rights, and sufficiency of evidence.The Kansas Supreme Court reviewed the case and found that the district court violated Trass' Sixth Amendment right to counsel by forcing him to represent himself without proper advisories or warnings about the dangers of self-representation. The court concluded that Trass did not waive his right to counsel knowingly and intelligently, nor did he forfeit it through egregious misconduct. The violation of Trass' right to counsel constituted structural error, requiring automatic reversal of his convictions. The court also found no violation of Trass' statutory right to a speedy trial and sufficient evidence to support his felony-murder conviction. The case was reversed and remanded for a new trial before a different judge. View "State v. Trass" on Justia Law

A father, H.S., was in federal custody during a hearing to terminate his parental rights to his child, A.S. He attended the hearing via Zoom, while the hearing was otherwise conducted in person. The father argued that his limited ability to participate in the hearing amounted to a due process violation.The Leavenworth District Court held a permanency hearing and concluded that reintegration was no longer a viable plan for A.S., and that permanent custodianship or adoption was in the child's best interests. Subsequently, the State moved to terminate the parental rights of both parents. During the termination hearing, the father attended remotely but was unable to testify or meaningfully participate. The district court found the father unfit and terminated his parental rights. The father appealed, claiming insufficient evidence and a due process violation. The Kansas Court of Appeals affirmed the district court's decision, rejecting the father's claims.The Kansas Supreme Court reviewed the case and focused on the due process claim. The court held that the father's due process rights were violated because he was not given the opportunity to testify, communicate with counsel, or otherwise fully participate in the hearing. The court emphasized that a parent's right to make decisions regarding the care, custody, and control of their child is a fundamental liberty interest protected by the Fourteenth Amendment. The court found that the risk of erroneous deprivation of this interest was high due to the procedures used, and that the State's interests did not justify the limitations placed on the father's participation.The Kansas Supreme Court reversed the judgments of the Court of Appeals and the district court, and remanded the case for a new termination hearing that ensures the father's due process rights are protected. View "In re A.S." on Justia Law

Williams Nunez was charged with rape for engaging in sexual intercourse with a person unable to consent due to intoxication. He admitted to the act but claimed the victim was not too intoxicated to consent. A jury convicted him, and the district court sentenced him to 155 months in prison with lifetime postrelease supervision, based on the finding that he was 18 years or older at the time of the crime.Nunez appealed, arguing that his Sixth Amendment rights under Apprendi v. New Jersey were violated because his age was not determined by the jury. The Kansas Court of Appeals affirmed his conviction and sentence, concluding that Nunez had sufficiently admitted his age through various documents and statements, and any Apprendi error was harmless.The Kansas Supreme Court reviewed the case to determine if Nunez's rights under Apprendi were violated. The court held that for a sentencing court to rely on a defendant's admission to increase a sentence, the admission must follow a knowing and voluntary waiver of the jury trial right. Since Nunez did not waive his jury trial rights regarding his age, the court found an Apprendi violation. The court also determined that the error was not harmless because the jury was not presented with evidence of Nunez's age.The Kansas Supreme Court reversed the Court of Appeals' decision, vacated the district court's sentence, and remanded the case for resentencing. The court directed that Nunez be sentenced to 60 months of postrelease supervision under K.S.A. 22-3717(d)(1)(G)(ii), as this was the appropriate term given the lack of a jury finding on his age. View "State v. Nunez" on Justia Law

Robert William Doelz was convicted of possession of methamphetamine with intent to distribute. In 2019, the Kansas Supreme Court reversed his conviction, finding that his Fourth Amendment rights were violated due to a warrantless search, and the evidence obtained should have been suppressed. On remand, the State dropped the charge and did not pursue a retrial. Subsequently, Doelz sought compensation for his wrongful conviction under K.S.A. 2020 Supp. 60-5004, which requires proving actual innocence among other criteria.The Shawnee District Court denied both parties' motions for summary judgment, interpreting K.S.A. 2023 Supp. 60-5004(c)(1)(C) to require a claimant to prove that their innocence resulted in the reversal of their conviction, dismissal of charges, or a not guilty verdict upon retrial. The court found that Doelz's conviction was reversed due to a Fourth Amendment violation, not because he did not commit the crime. Since there was no evidence explaining why the charges were dismissed, a material fact remained unresolved. At a bench trial, Doelz testified to his innocence, but the court granted the State's motion for judgment as a matter of law, finding that Doelz failed to prove the charges were dismissed due to his innocence.The Kansas Supreme Court affirmed the district court's decision. The court held that K.S.A. 2023 Supp. 60-5004(c)(1)(C) requires a claimant to prove actual innocence and that this innocence led to the reversal, dismissal, or acquittal. The court found that the legislative intent behind the statute was to compensate only those who are factually innocent. Since Doelz did not provide evidence that the charges were dismissed because of his innocence, he did not meet the statutory requirements for compensation. View "In the Matter of the Wrongful Conviction of Doelz" on Justia Law

Matthew Douglas Hutto pled guilty to two counts of felony murder and received two consecutive hard 25 life sentences. After sentencing, Hutto filed a pro se motion to withdraw his pleas, which the district court denied. Hutto appealed the denial, and the Kansas Supreme Court affirmed the district court's decision. Before the deadline to file a motion for rehearing or modification of the Supreme Court's decision, Hutto was subpoenaed to testify against his accomplice, Richard Daniel Showalter. Hutto invoked his Fifth Amendment privilege against self-incrimination and refused to testify. The district court ruled that Hutto no longer had the privilege and found him in contempt, imposing a six-month jail sanction.Hutto appealed the contempt finding, arguing that he retained his Fifth Amendment privilege because he had not exhausted all methods of attacking his convictions and sentences, including a potential motion for rehearing or modification and a possible habeas corpus motion. The Kansas Court of Appeals rejected Hutto's argument, holding that defendants lose their privilege against self-incrimination at sentencing when they plead guilty and do not move to withdraw their plea before sentencing. The appellate court affirmed the district court's finding of contempt.The Kansas Supreme Court reviewed the case and held that the proper standard to determine whether the Fifth Amendment privilege protects a witness from being compelled to testify is whether the testimony sought exposes the witness to a legitimate risk of incrimination, not a hypothetical or speculative one. The court overruled previous decisions that terminated the privilege at sentencing for guilty pleas. The court concluded that Hutto faced a legitimate risk of incrimination if forced to testify because he still had a legally viable opportunity to challenge the court's decision by filing a motion for rehearing or modification. Therefore, the court reversed the district court's order finding Hutto in contempt and vacated the six-month jail sanction. View "State v. Showalter" on Justia Law

The case involves a challenge to a series of statutes and implementing regulations ("Challenged Laws") relating to the licensure of abortion provider facilities in Kansas. The plaintiffs, an abortion care facility and its doctors, argued that the Challenged Laws infringed on a woman's fundamental right to personal autonomy, which includes the right to abortion, as protected under section 1 of the Kansas Constitution Bill of Rights. The district court agreed and issued a permanent injunction restraining the State from enforcing the Challenged Laws.The State appealed the decision, arguing that the Challenged Laws did not infringe on the right to abortion and that they survived strict scrutiny because they furthered the State's compelling interest in protecting maternal health and regulating the medical profession. The State also argued that the district court erred in striking down the Challenged Laws in their entirety, ignoring the statute's severability clause.The Supreme Court of the State of Kansas affirmed the district court's decision. The court held that the Challenged Laws did infringe on a woman's right to abortion and that the State failed to meet its burden to show that the laws furthered its stated compelling interests. The court also found it improper to sever the unconstitutional substantive licensure requirements from the statute. The court declined to address the equal protection issues raised by the State. View "Hodes v. Stanek" on Justia Law

The case involves a Kansas law, S.B. 95, which effectively bans a common method of second-trimester abortion known as Dilation and Evacuation (D & E), except when necessary to preserve the life of the pregnant woman or to prevent substantial and irreversible physical impairment of a major bodily function. The law was challenged by doctors who perform D & E abortions in Kansas, arguing that it violates the Kansas Constitution Bill of Rights.The district court granted a temporary injunction, concluding that the Kansas Constitution protects a right to abortion. The Court of Appeals affirmed the district court's decision, and the case was appealed to the Supreme Court of Kansas. The Supreme Court affirmed the temporary injunction, ruling that the Kansas Constitution Bill of Rights protects a right to choose whether to continue a pregnancy and that any government infringement of that right must withstand strict scrutiny. The case was remanded to the district court to apply this standard.On remand, the district court granted summary judgment for the doctors, holding that the law does not withstand strict scrutiny and consequently violated the Kansas Constitution Bill of Rights. The State appealed to the Supreme Court of Kansas.The Supreme Court of Kansas affirmed the district court's decision. The court held that the State failed to show that the law is narrowly tailored to further any compelling interest. The court struck down the law as an unconstitutional violation of section 1 of the Kansas Constitution Bill of Rights. View "Hodes v. Kobach" on Justia Law

The Supreme Court of Kansas reviewed a case involving the League of Women Voters of Kansas and other organizations against the Kansas Secretary of State and the Kansas Attorney General. The plaintiffs challenged three new Kansas election laws, alleging that they violated various provisions of the Kansas Constitution. The laws in question prohibited the false representation of an election official, prohibited election officials from counting advance ballots that did not have a signature or had a signature that an election official determined did not match the signature on file, and prohibited any person from collecting and returning more than 10 advance ballots for other voters.The case was initially heard in the Shawnee County District Court, which denied the plaintiffs' request for a temporary injunction against the false representation statute. The court also granted the defendants' motion to dismiss the claims against the signature verification requirement and the ballot collection restriction. The plaintiffs appealed these decisions, and the cases were consolidated.The Supreme Court of Kansas held that the plaintiffs had demonstrated a likelihood of prevailing on the merits of their claim that the false representation statute was constitutionally infirm. Therefore, the district court erred in denying their request for a temporary injunction. The court also held that the signature verification requirement was a valid effort by the Legislature to provide "proper proofs" of the right to be a qualified elector. However, the court remanded the case to the district court to consider whether the statute and its implementing regulations complied with the constitutional guarantees of equal protection and due process. Finally, the court affirmed the district court's grant of the defendants' motion to dismiss the claim that the ballot collection restriction was constitutionally infirm, because the restriction was not a new qualification on the right to be an elector, and because the proscribed activity—the delivery of ballots—was not political speech or expressive conduct. View "League of Women Voters of Kansas v. Schwab" on Justia Law

The defendant, John R. Cantu, was charged with multiple counts including felony stalking, violation of protection from stalking orders, criminal damage to property, criminal trespass, and felony criminal threat. During his trial, Cantu testified on his own behalf as the sole defense witness. However, during cross-examination, the judge removed Cantu from the stand for being uncooperative and, at the prosecutor's request, struck his entire testimony from the record. Cantu was subsequently convicted on several counts and appealed, arguing that the district court's decision to strike his entire testimony from the record deprived him of his constitutional right to testify, which was structural error requiring automatic reversal.The Court of Appeals agreed that the district court erred in ordering Cantu's testimony stricken from the record and that this error denied Cantu the constitutional right to testify. However, the panel held that the error was not structural, but could be analyzed using the harmless error standard. The panel concluded that the error was harmless and affirmed the convictions.The Supreme Court of the State of Kansas disagreed with the Court of Appeals' conclusion. The Supreme Court held that the complete and improper denial of a criminal defendant's constitutional right to testify is structural error. The court reasoned that the right to testify is a fundamental right grounded in multiple provisions of the United States Constitution. The court further explained that structural errors are defects affecting the fundamental fairness of the trial's mechanism, preventing the trial court from serving its basic function of determining guilt or innocence and depriving defendants of basic due process protections required in criminal proceedings. The court concluded that the complete and wrongful denial of a defendant's constitutional right to testify by improperly removing a defendant from the stand and striking the defendant's entire testimony is structural error because it renders the criminal trial fundamentally unfair, regardless of whether the outcome of the trial would have been different had the defendant been permitted to testify and his or her testimony been left intact. Therefore, the Supreme Court reversed Cantu's convictions and remanded for a new trial. View "State v. Cantu" on Justia Law