Justia Constitutional Law Opinion Summaries

Articles Posted in Kansas Supreme Court
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The Supreme Court affirmed Defendant's conviction of aggravated indecent liberties with a child, holding that Defendant was not entitled to relief on any of his claims of error.Specifically, the Supreme Court held (1) the district court's exclusion of polygraph evidence did not violate Defendant's constitutional right to present a complete defense; (2) the district court did not abuse its discretion by allowing the State to amend the information; (3) although the admission of Defendant's videotaped confession to a previous offense may have been inflammatory, any error was harmless; and (4) cumulative error did not deny Defendant a fair trial. View "State v. White" 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 denying Defendant's motion to suppress evidence obtained during a search that led to the State charging Defendant with possession of drugs and drug paraphernalia with the intent to distribute, holding that the district court properly denied the suppression motion.This appeal arose after police officers detained Defendant while he sat in a minivan in an alleyway. Defendant filed a motion to suppress the evidence obtained during the search, arguing that the seizure of the minivan violated his constitutional rights. The district court concluded that the detention was reasonable and justified under the public safety exception to the warrant requirement. The court of appeals affirmed. The Supreme Court affirmed, holding that the seizure of the minivan was reasonable under the Fourth Amendment and section 15 of the Kansas Constitution Bill of Rights. View "State v. Bates" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the decision of the trial court judge dismissing this case with prejudice after suppressing evidence as a discovery sanction, holding that, under the circumstances, the district court did not abuse its discretion in dismissing the case with prejudice.Defendant was charged with drug-related offenses. The district court ultimately dismissed the charges with prejudice after suppressing certain evidence as a discovery sanction. The court of appeals reversed and remanded hte case, concluding that the district court abused its discretion by dismissing the case with prejudice for a discovery failure. The Supreme Court reversed, holding (1) the judge infringed on the prosecutor's discretion by not leaving to the prosecutor the decision of whether to proceed to trial; and (2) the error was harmless. View "State v. Mulleneaux" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of a panel of the court of appeals affirming Defendant's conviction of possession of more than 3.5 grams of methamphetamine with intent to distribute, possession of a firearm within ten years of a prior felony conviction, and two counts of drug paraphernalia possession, holding that insufficient evidence supported Defendant's firearm possession conviction.On appeal, Defendant raised six allegations of error. The Supreme Court reversed in part, holding (1) the panel erred when it refused to consider for the first time on appeal the legal appropriateness of an intent-to-distribute instruction and the instruction's permissive inference was legally inappropriate, but this error was not prejudicial; (2) Defendant's constitutional challenges failed; (3) there was insufficient evidence to support Defendant's firearm conviction; and (4) Defendant was not entitled to relief on his remaining claims of error. View "State v. Valdez" on Justia Law

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The Supreme Court reversed the judgment of the lower court finding the legislative reapportionment in the map colloquially known as "Ad Astra 2" constitutionally deficient as a partisan and racial gerrymander, holding that Plaintiffs did not prevail on any of their claims that Ad Astra 2 violates the Kansas Constitution.The district court held that Sub. SB 355 violates the Kansas Constitution as both a partisan and a racial gerrymander. The Supreme Court reversed, holding (1) this Court had jurisdiction to hear Plaintiffs' claims; (2) claims of excessive partisan gerrymandering are nonjusticiable in Kansas; and (3) Plaintiffs did not establish the elements of their race-based claims. View "Rivera v. Schwab" on Justia Law

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The Supreme Court upheld the validity of Substitute for Senate Bill 563 (Sub. SB 563), holding that the Kansas State House and Kansas State Senate reapportionment maps contained within Sub. SB 563 contain no constitutional errors.The two maps at issue were approved by bipartisan majorities, and Sub. SB 563 was signed into law on April 15, 2022. On April 25, Attorney General Derek Schmidt petitioned the Supreme Court to determine the validity of Sub. SB 563, as required by Kan. Const. art. 10, 1(b). The Supreme Court held that Sub. SB 563 passed constitutional muster because the legislative maps contained therein satisfied the constitutional requirement of one person one vote, they were not discriminatory, and they satisfied the requirements of the Voting Rights Act. View "In re Validity of Substitute for Senate Bill 563" on Justia Law

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The Supreme Court affirmed Defendant's convictions for felony murder and aggravated robbery, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued that the indictment forming the basis of his conviction was statutorily and constitutionally defective, that the district court erred in several respects, and that the cumulative effect of those errors violated his constitutional right to a fair trial. The Supreme Court affirmed, holding (1) the second superseding indictment did not implicate Kan. Stat. Ann. 22-3015 or deprive Defendant of due process; (2) the district court did not err in denying Defendant's motion to dismiss or in admitting into evidence the deposition testimony of a witness unavailable to testify at trial; (3) Defendant was not entitled to a self-defense instruction; and (4) where there was no error, the cumulative doctrine did not apply. View "State v. Keys" on Justia Law

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The Supreme Court affirmed Defendant's convictions of felony possession of methamphetamine, misdemeanor possession of drug paraphernalia with intent to use, and misdemeanor theft, holding that the district court did not err in denying Defendant's motion to suppress.Defendant was detained at Walmart for trying to leave the store without paying for merchandise. Defendant was arrested and taken to jail, where a booking deputy conduct an inventory search of Defendant's possessions. Upon discovering illicit drugs the deputy did a strip search of Defendant's person, discovering more illicit drugs. Defendant moved to suppress the drugs and paraphernalia based on an illegal misdemeanor arrest. The motion was denied, and Defendant was convicted. On appeal, Defendant argued that the evidence should have been suppressed because the officer illegally arrested her rather than issuing her a notice to appear. The Supreme Court affirmed, holding that the officer had probable cause to believe Defendant committed misdemeanor theft and would not be apprehended. View "State v. Goodro" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's motions filed under Kan. Stat. Ann. 60-1507 and Kan. Stat. Ann. 22-3504, holding that Defendant's section 60-1507 motion was untimely and successive and that Defendant's sentence was not illegal.In 2003, Defendant was convicted by a jury of first-degree murder and sentenced to a hard fifty life sentence. Since his conviction, Defendant filed multiple collateral attacks on his sentence and conviction, all of which were unsuccessful. In the motions at issue on appeal, Defendant alleged that his sentence was unconstitutional under Apprendi v. New Jersey, 530 U.S. 466 (2000) and that this Court's failure to correct his sentence violated Kan. Stat. Ann. 21-6628(c). The district court denied both motions. The Supreme Court affirmed, holding that the district court did not err in denying the motions. View "Drennan v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's pro se motion to correct an illegal sentence, holding that the district court did not err in summarily denying Defendant's motion.A jury convicted Defendant of aggravated burglary, aggravated kidnapping, rape, and two counts of aggravated sodomy. Defendant later filed a pro se motion to correct an illegal sentence under Kan. Stat. Ann. 22-3504, arguing that his sentence was illegal because he was denied his statutory right to a speedy trial and his right to allocution at sentencing. The district court denied the motion without holding an evidentiary hearing. The Supreme Court affirmed, holding that neither of Defendant's claims was properly before the court in a motion to correct an illegal sentence. View "State v. Mitchell" on Justia Law