Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the decision of the district court determining that Appellant's claim for attorney fees and expenses should be decided by the court and not a jury, holding that Section 5 of the Kansas Constitution Bill of Rights does not guarantee the right to a jury trial to determine an award of attorney fees and expenses.The two cases leading to the attorney fee dispute arose of the sale of real property to Appellant. The first lawsuit was filed in 2013, and the second lawsuit was filed in 2015. After the case was decided, the district court denied Appellant's request for a jury trial on the issue of attorney fees and expenses, determining that the issue would be heard by the court and not by a jury. The Supreme Court affirmed, holding (1) the Kansas Constitution does not guarantee the right to a jury trial to determine whether attorney fees and expenses should be award; (2) Appellant waived her request for a jury trial to determine attorney fees in the 2013 case; and (3) Appellant's claim for attorney fees under the third-party litigation exception to the American rule is an equitable claim that should be decided by the court rather than a jury. View "Harder v. Estate of Foster " on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's challenge to the constitutionality of his sentence, holding that because Defendant did not object to the district court's failure to make factual findings at sentencing and he did not file a motion under Kansas Supreme Court Rule 165, Defendant's as-applied challenge to the constitutionality of his sentence was not amenable to appellate review.Defendant pleaded guilty to first-degree felony murder, an off-grid person felony mandating a hard twenty-five sentence. Before sentencing, Defendant argued that his hard twenty-five sentence was unconstitutional as applied to the facts of his case under section 9 of the Kansas Constitution Bill of Rights. The district court found the sentence constitutional. The Supreme Court affirmed, holding that because Defendant failed to meet his obligation to ensure the district court made the factual findings necessary for appellate review, Defendant failed to preserve his as-applied constitutional challenge for appellate review. View "State v. Espinoza" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction of possession fo marijuana, holding that Defendant's waiver of jury trial was legally insufficient.On appeal, Defendant argued that he did not properly waive his right to a jury and asserted three other issues. The Supreme Court reversed the judgment of the court of appeals affirming Defendant's convictions without addressing the three remaining issues, holding that because the district court failed properly to apprise Defendant of his right to a jury trial and failed to ensure that Defendant understood the nature of the right he was giving up, Defendant's constitutional right to a jury trial was violated in this case. View "State v. Harris" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree murder, kidnapping, and aggravated interference with parental custody, holding that Defendant's post-arrest confession was voluntary and that any violation of Defendant's due process rights was harmless.On appeal, Defendant argued that her confession was involuntary and that its admission at trial was reversible error. Defendant also argued that the State violated her due process rights at trial by mentioning her invocation of her rights. The Supreme Court disagreed, holding (1) substantial competent evidence supported the foundation of the district court's decision that Defendant's confession was voluntary and admissible; and (2) where the State thoroughly undermined Defendant's credibility, any fleeting mention of Defendant's invocation of her rights was harmless error. View "State v. Sesmas" on Justia Law

The Supreme Court affirmed the judgment of the district court judge granting in part and denying in part Defendant's motion to correct an illegal sentence, holding that this Court cannot consider the merits of Defendant's constitutional arguments because a motion to correct an illegal sentence is an improper vehicle for them.Defendant was sentenced to life imprisonment without the possibility for parole for twenty-five years, known as a hard twenty-five, upon his plea of no contest to first-degree murder. Defendant later filed a motion to correct an illegal sentence, arguing that his hard twenty-five was constitutionally disproportionate and that the district judge erred by imposing lifetime postrelease supervision. The district court agreed that Defendant should not be subject to lifetime postrelease supervision but rejected Defendant's constitutional challenge. Defendant appealed, arguing that his hard twenty-five was disproportionate under the state and federal constitutions. The Supreme Court affirmed, holding that a motion to correct an illegal sentence cannot raise claims that a sentence violates a constitutional provision. View "State v. Peterson" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentence arising from an armed robbery in which a victim was killed by an accomplice, holding that there was no error or abuse of discretion in the proceedings below.Specifically, the Supreme Court held (1) Defendant's felony-murder conviction did not violate due process because the felony-murder statute does not remove from the jury's consideration an intent element required by criminal statute; (2) the district court did not commit clear error when it instructed the jury to apply the law if the State proved all elements of the charged offenses; (3) the prosecutor did not commit error during voir dire by saying that an empaneled jury could not "debate" the law; (4) Defendant's constitutional challenges to his hard twenty-five life sentence were unavailing; and (5) Defendant's Apprendi challenge to the use of criminal history scores was without merit. View "State v. Patterson" on Justia Law

The Supreme Court affirmed in part the decision of the court of appeals reversing Defendant conviction based on a violation of the right to jury trial but affirming the district court's denial of Defendant's motion to suppress, holding that the court of appeals did not err in agreeing with the district court's conclusion that the officer had probable cause to support a reasonable belief that Defendant had been driving while intoxicated beyond the legal limit.Defendant was convicted of aggravated battery while driving under the influence of alcohol. The district court denied Defendant's motion to suppress evidence obtained from a warrantless blood draw. The court of appeals reversed the conviction but affirmed the denial of the motion to suppress, concluding that the factors in this case supported probable cause. The Supreme Court affirmed in part, holding (1) probable cause existed in this case; and (2) as to the issue of whether the warrantless blood draw was justified by exigent circumstances the case must be remanded for an evidentiary hearing and a ruling from the district court on exigency in light of Mitchell v. Wisconsin, 588 U.S. __ (2019). View "State v. Chavez-Majors" on Justia Law

The Supreme Court affirmed Defendant's convictions for robbery, kidnapping, and criminal threat, holding that the court of appeals panel property found that any trial errors were harmless both individually and collectively.On appeal, the panel denied Defendant's ineffective assistance of counsel claim and affirmed the convictions, concluding that two trial errors were harmless. The Supreme Court affirmed, although its reasoning differed from the panel's, holding (1) there was sufficient evidence supporting the robbery conviction; (2) there was error in two of the jury instructions, but the verdict would not have been different without the errors; (3) the cumulative effect of the instructional errors did not require reversal; and (4) Defendant did not suffer prejudice on his ineffective assistance of counsel claim. View "State v. Harris" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, holding that, even if the Court find one error and assume the existence of another, these errors did not, individually or collectively, require reversal of Defendant's conviction.Specifically, the Court held (1) the prosecutor use of the phrase "I think" qualified as error, but this brief indiscretion did not merit reversal; (2) even if the district court erred in failing to instruct sua sponte on reckless second-degree murder and reckless involuntary manslaughter, the error was not clear; (3) Defendant's remaining allegations of error were without merit; and (4) the errors - one identified and one assumed - did not cumulatively prejudice Defendant and did not deprive him of a fair trial. View "State v. Pruitt" on Justia Law

The Supreme Court affirmed the judgment of the district court rejecting Appellant's argument that a nineteen-month delay between his arrest and trial violated his constitutional right to a speedy trial, holding that Appellant failed to establish a violation of his constitutional right to a speedy trial as guaranteed by the Sixth Amendment to the United States Constitution and section 10 of the Kansas Constitution Bill of Rights.In support of his argument, Appellant contended that the court of appeals erred in ruling that the six months he spent in juvenile detention should not be counted in determining the length of the delay. The Supreme Court affirmed, holding (1) the right to a speedy trial applies in juvenile offender proceedings, and therefore, Appellant's period of juvenile detention should be included in a calculation of how long it took to get to trial; but (2) Appellant's constitutional right to a speedy trial was not violated, even considering the full nineteen-month delay rather than the thirteen months considered by the court of appeals. View "State v. Owens" on Justia Law