Justia Constitutional Law Opinion Summaries

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court suppressing derived from a search because it found that the search resulted directly from a police officer's unconstitutional seizure of Defendant, holding that this case must be remanded to the district court for further findings of fact.Applying the attenuation doctrine factors set forth by the United States Supreme Court, the district court suppressed the evidence at issue. The court of appeals reversed the district court's ultimate decision, finding that an intervening circumstance attenuated the taint of the unlawful seizure and thus did not invalidate the later search. The Supreme Court reversed, holding (1) the district court erred in failing to consider the officer's discovery of an arrest warrant as a circumstance that intervened between the officer's illegal detention of Defendant and his search of her purse after arresting her; and (2) because there remained unanswered questions of fact, the case is remanded for the district court to make the appropriate findings of fact under the correct legal standard. View "State v. Tatro" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's convictions and sentences, holding that a police officer's discovery of an expired tag on Defendant's vehicle did not present an intervening circumstance that attenuated the taint of the officer's unconstitutional seizure of Defendant.Defendant was unconstitutionally detained by a police officer. Defendant filed a motion to suppress, arguing that officers obtained incriminating evidence as the result of an unlawful seizure. The district court denied the motion. The court of appeals reversed, finding that Defendant's initial seizure was unsupported by reasonable suspicion but that the United States Supreme Court's attenuation doctrine analysis in Utah v. Strieff, 579 U.S. __ (2016), applied to allow the admission of the evidence. The Supreme Court reversed, holding that there was no attenuation of the taint of the illegal seizure, and therefore, the district court erred by denying Defendant's motion to suppress. View "State v. Christian" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court's summary denial of Defendant's Kan. Stat. Ann. 60-1507 motion, holding that summary denial of the section 60-1507 motion was appropriate in this case.On appeal, the court of appeals concluded that the district court erred in elying upon the State attorney's written response to Defendant's pro se motion without first appointing counsel for Defendant but that the error was harmless because the record conclusively established the Defendant was not entitled to relief. The Supreme Court affirmed while disagreeing with the court of appeals' resolution of the right to counsel issue, holding (1) the State's filing of a written response, standing alone, did not trigger Defendant's statutory right to counsel; and (2) the substantive claims Defendant raised in his section 60-1507 motion did not warrant relief. View "Stewart v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court summarily denying Defendant's fourth Kan. Stat. Ann. 60-1507 motion, holding that there was no error in the proceedings below.The district court summarily denied Defendant's fourth motion as untimely, successive, and an abuse of remedy. The court of appeals affirmed, holding that Defendant's motion was barred as successive and an abuse of remedy because Defendant failed to show exceptional circumstances allowing him to raise his claims in his fourth section 60-1507 motion. The Supreme Court affirmed, holding (1) the failure to appoint counsel for Defendant did not violate his due process rights; and (2) the court of appeals did not err in affirming the district court's finding that Defendant failed to establish exceptional circumstances to permit a merits review of his successive section 60-1507 motion. View "Dawson v. State" on Justia Law

The Supreme Court reversed the judgment of the district court issuing a permanent injunction preventing enforcement of an ordinance passed by the City of Topeka making it unlawful for any person to sell cigarettes, electronic cigarettes, tobacco products or liquid nicotine to any person under twenty-one years of age or for any person to buy such items for any person under twenty-one years of age, holding that the ordinance is not preempted and does not conflict with the Kansas Cigarette and Tobacco Products Act, Kan. Stat. Ann. 79-3301 et seq.Specifically, the Supreme Court held (1) the ordinance is a constitutionally valid exercise of the City's home rule power under article 12, section 5 of the Kansas Constitution; and (2) the Act does not preempt cities from regulating tobacco products, and the ordinance does not conflict with the Act by imposing greater restrictions. View "DWAGFYS Manufacturing, Inc. v. City of Topeka" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of a majority of the court of appeals panel reversing in part and affirming in part the district court's decision on Defendant's motion to suppress evidence, holding that neither Defendant's pre-Miranda statement nor his post-Miranda statement were admissible in evidence.The district court found admissible Defendant's pre-Miranda statement that he had marijuana on his person but suppressed Defendant's pre-Miranda statement that he had marijuana in his car. The district court also ruled that Defendant's post-Miranda statements were admissible because at that point Defendant had voluntarily waived his rights. The court then ruled that Defendant's pre-Miranda statement about the marijuana on his person was admissible and that the doctrines of plain view and inevitable discovery applied to the evidence in Defendant's car. The court of appeals set aside Defendant's convictions and ordered a new trial, holding that the district court erred in denying Defendant's motion to suppress his post-Miranda statement as coerced. The Supreme Court reversed in part, holding (1) the pre-Miranda statement Defendant made surrounding his initial pat-down was not admissible as evidence because he was being interrogated in custody at the time; and (2) Defendant's post-Miranda statement was inadmissible due to implied physical violence toward Defendant. View "State v. Guein" on Justia Law

The Supreme Court affirmed the decision of the court of appeals ruling that Petitioner's pro se motion quoting Kansas Rules of Professional Conduct (KRPC) 1.3 did not trigger the district court's duty to inquire into a potential conflict between Petitioner and his appointed attorney, holding that, assuming error, there was no showing of prejudice.Petitioner was charged with two counts of commercial sexual exploitation of a child. The district court determined that Petitioner was indigent and appointed a public defender to represent him. The jury found Defendant guilty of one count of commercial sexual exploitation of a child. Thereafter, Petitioner filed a motion for a new trial, arguing that the district court erred by failing to inquire into his pro se motions voicing dissatisfaction with counsel. The district court denied the motion on the grounds that Petitioner's pro se documents did not convey a request for new counsel. The court of appeals affirmed, concluding that Petitioner's pro se motions quoting KRPC 1.3 did not allege dissatisfaction with counsel. The Supreme Court affirmed, holding that, assuming that the district court abused its discretion when it failed to inquire about Petitioner's dissatisfaction with counsel, Petitioner's alleged conflict with counsel did not prejudice Defendant in any way. View "State v. Bacon" on Justia Law

The Supreme Court affirmed Defendant's convictions of first-degree murder under theories of premeditation and felony murder, attempted first-degree murder, and other offenses, holding that the district court did not err in the proceedings below.Specifically, the Court held (1) the district court did not err in concluding that Defendant was not entitled to a change of venue under Kan. Stat. Ann. 22-2616; and (2) the district court did not violate Defendant's Fifth Amendment rights when it denied Defendant's motion to suppress his confession because Defendant knowingly and intelligently waived his previously invoked right to counsel and because the confession was voluntary. View "State v. Palacio" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to suppress evidence on the ground that incriminating evidence was obtained as the result of an unlawful seizure, holding that officers unlawfully detained Defendant and conducted an illegal search.Defendant was seated in a car lawfully parked in an apartment complex parking lot when two officers approached the car. Defendant's hands were clenched and held in front of him, and one officer commanded Defendant to open his hand. Defendant opened his hand and dropped a small bag of cocaine. Defendant moved to suppress the evidence, but the district court denied the motion, finding that the encounter was voluntary. The court of appeals affirmed. The Supreme Court reversed and remanded for further proceedings, holding that the detention was unlawful because the officer lacked reasonable suspicion of criminal activity to detain Defendant, and therefore, the evidence obtained as a result must be suppressed because it was tainted by an unlawful seizure. View "State v. Andrade-Reyes" on Justia Law

The Supreme Court held that through Senate Bill 16's (S.B. 16) additional funding of the State's "Montoy safe harbor plan," the State substantially complied with this Court's mandate from Gannon v. State, 420 P.3d 477 (Kan. 2018) (Gannon VI).In Gannon VI, the Supreme Court held that the State had resolved nearly all of the issues in this school finance appeal but that the State had not met Kan. Const. Art. 6, 6(b)'s adequacy requirement. The Supreme Court retained jurisdiction and stayed the issuance of its mandate in order to give the State ample opportunity to make the necessary financial adjustments and reach constitutional compliance. The State subsequently passed S.B. 16, which the Governor signed into law on April 6, 2019. The Supreme Court held that the State substantially complied with the Court's Gannon VI mandate through S.B. 16's financial adjustments to the safe harbor plan. The Court retained jurisdiction to ensure continued implementation of the scheduled funding. View "Gannon v. State" on Justia Law