Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the district court’s summary denial of Appellant’s motion to correct an illegal sentence, holding that this motion was not the appropriate procedural vehicle for Appellant to raise his claim.Appellant filed his motion to correct an illegal sentence approximately nineteen years after he was convicted of second-degree murder. In his motion, Appellant argued that his sentence of life imprisonment with a mandatory ten-year term violated the Eighth Amendment because he was under the age of eighteen when he committed the crime. The district court summarily denied the motion. The Supreme Court affirmed, thus declining to overrule long-established caselaw codified into statute that a motion to correct an illegal sentence cannot raise claims that the sentence violates a constitutional provision. View "State v. Samuel" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the district court’s denial of Defendant’s motion to suppress the fruits of a vehicle search, holding that the general search of Defendant’s vehicle was an unconstitutional warrantless search.The vehicle Defendant was driving was stopped by a law enforcement officer to investigate whether the vehicle had any connection to a recent bank robbery. After seizing a digital scale from the back seat, the officer searched the vehicle. After a second trial, Defendant was convicted of possession of methamphetamine with intent to distribute. The court of appeals affirmed. The Supreme Court reversed and remanded the matter for a new trial, holding (1) the search of the box that contained the digital scale retrieved from the vehicle’s back seat was unlawful, and the district court erred in refusing to suppress the evidence of the digital scale; and (2) the district court erred in finding that the automobile exception to the warrant requirement applied to the search of the entire vehicle in this case. View "State v. Doelz" on Justia Law

The Supreme Court reversed the judgment of the Court of Appeals holding that the trial court abused its discretion in not granting Defendant a new trial because of the State’s exercise of a peremptory strike that removed an individual with a Spanish surname from the jury panel, holding that Defendant failed to establish that the trial court abused its discretion in denying Defendant’s motion for new trial.The district court determined that the state had a race-neutral reason for striking the potential juror. Because one of the State’s reasons was race-neutral, the district court denied Defendant’s objection to the State’s peremptory strike. After Defendant was convicted, the Court of Appeals determined that the circumstances showed the peremptory strike was not race-neutral. The Supreme Court reversed, holding that the trial court properly found that the State honestly believed the factual basis it first offered as the reason for its strike and that the reason was not a pretext. Therefore, Defendant failed to meet his burden of establishing that the State exercised its peremptory strikes based on purposeful racial discrimination. View "State v. Gonzalez-Sandoval" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the district court’s order suppressing drug-related evidence seized during a residential search supported by a warrant, holding that the affidavit facts provided a substantial basis for the issuing judge’s determination that there was a fair probability that evidence of illegal marijuana possession would be found in the home.Specifically, the Court held (1) Miranda warnings were required before Defendant made incriminating statements used to support the warrant, and therefore, the incriminating statements were properly suppressed where the warnings were not given before the statements were made; but (2) the officer’s testimony that he executed the smell of raw marijuana coming from the residence provided the probable cause for the search warrant. View "State v. Regelman" on Justia Law

The Supreme Court affirmed Defendant’s misdemeanor convictions of possession of marijuana and possession of drug paraphernalia, holding that the totality of the circumstances surrounding a police officer’s detection of the smell of raw marijuana emanating from a residence can supply probable cause to believe that the residence contains contraband or evidence of a crime.On appeal, Defendant argued that his motion to suppress should have been granted because police officers’ warrantless entry into his residence, purportedly for officer safety and to prevent evidence destruction, violated the Fourth and Fourteenth Amendments. The court of appeals affirmed but stopped short of finding that the odor of marijuana would have provided probable cause for officers to conduct a search of Defendant’s apartment because that search occurred after a warrant was issued. The Supreme Court affirmed, holding (1) probable cause plus the exigent circumstances exception permitted the initial warrantless entry into Defendant’s apartment for a security sweep; and (2) to the extent the drug paraphernalia evidence and the search warrant were fruits of a warrantless search, the sweep was not illegal and the challenged evidence was not subject to exclusion. View "State v. Hubbard" on Justia Law

The Supreme Court affirmed Defendant’s convictions of possession of cocaine, fleeing or attempting to elude a police officer, and related offenses, holding primarily that the trial court did not err in refusing to suppress drug evidence found in Defendant’s vehicle after a police officer’s warrantless search.Specifically, the Court held (1) the initial seizure of Defendant’s person did not violate his Fourth Amendment rights, and his extended holding in the police car did not make his seizure illegal; (2) even if there were an initial vehicle seizure when pulling Defendant over to effect his arrest, that seizure ended when Defendant parked the car, got out, locked it, and stated he would not consent to its search; and (3) the evidence was sufficient to support Defendant’s fleeing conviction. View "State v. Parker" on Justia Law

The Supreme Court affirmed Defendant’s sentence of life without the possibility of parole for fifty years (hard fifty sentence), holding that the district court’s retroactive application of Kan. Stat. Ann. 21-6620 did not violate the prohibition on ex post facto laws.Defendant was convicted of first-degree premeditated murder and sentenced to a hard fifty sentence. The Supreme Court vacated the hard fifty sentence and remanded. On remand, the district court again imposed a hard fifty sentence. Defendant appealed the district court’s determination that it could retroactively apply the hard fifty sentencing procedures of section 21-6620. The Supreme Court affirmed, holding that the retroactive application of the hard fifty sentencing procedures in section 21-6620 to Defendant’s resentencing did not violate the Ex Post Facto Clause. View "State v. Hayes" on Justia Law

The Supreme Court affirmed Defendant’s convictions for child abuse and felony murder, holding that the instances of prosecutorial error in this case did not require reversal, either individually or cumulatively.Specifically, the Court held that the prosecutor exceeded the wide latitude afforded to prosecutors on three occasions during closing argument, but the State proved beyond a reasonable doubt that the error did not affect the trial’s outcome in light of the entire record. Further, the Court held that the cumulative effective of the claimed errors did not deprive Defendant of a fair trial. View "State v. Anderson" on Justia Law

The Supreme Court affirmed Defendant’s conviction of premeditated first-degree murder on retrial and his hard-twenty-five life sentence, holding that Defendant was not prejudiced by any errors so as to deny him a fair trial.In 2005, Defendant was convicted of premeditated first-degree murder. In 2012, the Court of Appeals granted Defendant's motion for postconviction relief and ordered a new trial. Upon retrial, a new jury also convicted Defendant of premeditated first-degree murder. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that actual prejudice from pretrial publicity mandated a reversal of his conviction; (2) Defendant failed to establish he was prejudiced by the trial court’s denial of his for-cause challenges to ten prospective jurors; (3) any error in the prosecutor’s violation of a limine order prohibiting any mention of pornography was harmless; and (4) Defendant was not substantially prejudiced by the cumulative effect of multiple errors. View "State v. Miller" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the district court’s modification of its originally ordered period of postrelease supervision after the original term of supervision had ended and vacated Defendant’s sentence, holding that Defendant was entitled to be discharged from custody.The Court held that because the original sentence had been completely served when the district court purported to correct Defendant’s sentence, the imposition of a new sentence was precluded by the double jeopardy provisions of the Fifth Amendment to the United States Constitution and section 10 of the Kansas Constitution Bill of Rights. The Court remanded this case with directions to discharge Defendant. View "State v. Lehman" on Justia Law