Justia Constitutional Law Opinion Summaries

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

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

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

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

The Supreme Court affirmed as right for the wrong reason the judgment of the court of appeals holding that harmless constitutional error occurred when the district court responded to a jury question by having court staff deliver a written note to the jury room rather than convening in open court and answering the question in Defendant's presence, holding that no constitutional error occurred.Specifically, the court of appeals held that the district court violated Defendant's constitutional right to be present at a critical stage in the proceedings by responding in writing to the jury rather than giving the answer with Defendant present in the open court but that the error was harmless. The Supreme Court affirmed, holding (1) Kan. Stat. Ann. 22-3420(d) gave the district court discretion to deliver a written response to the jury room without having Defendant present; and (2) no constitutional error occurred in this case. View "State v. Harrison" on Justia Law

The Supreme Court held that the uncertainty in the residual phrase in Kan. Stat. Ann. 21-6304 defining a knife as "a dagger, dirk, switchblade, stiletto, straight-edged razor or any other dangerous or deadly cutting instrument of life character" is so great that the law is impermissibly and unconstitutionally vague.Defendant, a convicted felon, was found guilty of criminal possession of a weapon stemming from his act of pulling out a pocketknife when he got into an altercation with another man. On appeal, Defendant argued that the district court erred by rejecting his vagueness challenge to section 21-6304, which makes it a crime for a convicted felon to possess a knife. The court of appeals affirmed. The Supreme Court reversed Defendant's conviction, holding that section 21-6304 invites "varying and unpredictable" enforcement decisions on an "ad hoc and subjective basis" and, therefore, the residual clause in section 21-6304 is unconstitutionally vague. View "State v. Harris" on Justia Law

In this appeal from the termination of Father's parental rights consequent to an adoption, the Supreme Court affirmed the opinion of the court of appeals affirming the termination, holding that the district court correctly terminated Father's parental rights and that Father's constitutional challenge to Kan. Stat. Ann. 59-2136 was not preserved for review.In his petition for review, Father challenged the factual basis for the termination order and also challenged, for the first time, the constitutionality of Kan. Stat. Ann. 59-2136(h)(1)(D), on which the termination was based. The Supreme Court affirmed, holding (1) this Court declines to address the constitutional issue because it was raised neither in the district court nor in the court of appeals; and (2) the court of appeals correctly upheld the district court's finding that Father failed to support the mother during the last six months of her pregnancy without reasonable cause excusing the lack of support. View "In re Adoption of Baby Girl G." on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder, attempted distribution of a controlled substance, attempted aggravated robbery, aggravated assault, and criminal possession of a firearm, holding that any error resulting from the district court's exclusion of certain testimony was harmless.Specifically, the Supreme Court held (1) Defendant's convictions were not multiplicitous; (2) Defendant's argument that the State committed prosecutorial error when it made certain comments during its cross-examination of a certain witness was in essence an evidentiary question not properly preserved for appeal; (3) the district court's error in upholding a witness's invocation of his Fifth Amendment privilege and excluding his testimony, if any, was harmless; and (4) the cumulative doctrine did not apply. View "State v. George" on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendant's postsentencing motion to withdraw his guilty plea after it found that the record conclusively showed Defendant's plea was knowing and voluntarily made, holding that the district court correctly denied the motion.Defendant pled guilty to premeditated first-degree murder, aggravated robbery, felony theft, forgery, and misdemeanor theft. In his motion to withdraw his guilty plea, Defendant argued that he had a mental illness that rendered his plea involuntary. The district court denied the motion. On appeal, Defendant argued that the district court erred in denying his motion without an evidentiary hearing and that his counsel was ineffective because he did not have Defendant undergo a mental health evaluation. The Supreme Court affirmed, holding (1) Defendant failed to show the manifest injustice necessary to allow him to withdraw his plea; and (2) counsel's decision to forgo a mental health evaluation did not constitute deficient representation. View "State v. Adams" on Justia Law

The Supreme Court vacated its judgment reversing the judgment of the court of appeals, which reversed the district court's ruling granting Defendant's motion to suppress evidence obtained during a traffic stop, holding that the district court's judgment is affirmed in accordance with the decision of the United States Supreme Court.The district court determined that the officer lacked reasonable suspicion of illegal activity when he stopped the vehicle, making the seizure of Defendant a violation of his Fourth Amendment rights. The court of appeals reversed. The Supreme Court reversed the court of appeals. The United States Supreme Court granted the State's petition for a writ of certiorari and reversed, holding that the investigative traffic stop was reasonable under the Fourth Amendment. Accordingly, the Kansas Supreme Court vacated its judgment reversing the court of appeals and remanded for further proceedings. View "State v. Glover" on Justia Law