Justia Constitutional Law Opinion Summaries

Articles Posted in Kansas Supreme Court
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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

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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

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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

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The Supreme Court reversed the decision of the court of appeals concluding that the district court committed harmless error in failing to suppress a blood test result, holding that the court of appeals erred when it concluded that Defendant could be guilty of an alternative charge.Following a bench trial on stipulated facts, the district court convicted Defendant of driving with a blood alcohol content of more than 0.08 as measured within three hours of driving. The court of appeals affirmed, holding that, even though the district court should have suppressed the blood test result, the stipulation included facts that supported a conviction on an alternative charge that was not a part of the district court's judgment. The Supreme Court reversed, holding that the court of appeals erred by not considering and applying the conditions that limited the binding nature of the parties' stipulation. View "State v. Braun" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, holding that there was a single instance of prosecutorial error during closing argument, but the error was harmless beyond a reasonable doubt.Specifically, the Supreme Court held (1) the district court judge did not err by denying Defendant's motion to suppress incriminating statements made during his police interview; (2) the district judge did not err by refusing to give voluntary intoxication instructions; (3) the prosecutor committed error in closing argument, but the error was harmless; and (4) because this Court identified only one error, the cumulative error doctrine did not apply. View "State v. Moore" on Justia Law

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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

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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

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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

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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

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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