Justia Constitutional Law Opinion Summaries

The case involves a juvenile, J.L.J., who was charged with first-degree felony murder and several other offenses after he opened fire on a car, killing a 12-year-old boy. J.L.J. was certified for adult prosecution and testified that he was acting in self-defense. The jury rejected his self-defense claim and convicted him on all charges.The case was previously heard in the Leavenworth District Court where J.L.J. was convicted. On appeal, J.L.J. raised several claims of error, including prosecutorial errors and the argument that the State unconstitutionally pitted his right to prepare for his defense against his right to testify at trial.The Supreme Court of the State of Kansas affirmed the lower court's decision. The court found that while the prosecutor erred by asking potential jurors if they would do their "job" and convict J.L.J., this error was harmless and did not affect the jury's verdict. The court also disagreed with J.L.J.'s argument that the prosecutor misstated the law on self-defense during closing argument. Furthermore, the court found that the State's impeachment of J.L.J. did not violate the unconstitutional-conditions doctrine. Lastly, the court declined to invoke an exception to the general preservation rule to address J.L.J.'s argument that the adult certification process violates his constitutional rights. View "State v. J.L.J." on Justia Law

In Kansas, Miles Loren Martin was convicted of possession of methamphetamine and possession of a controlled substance without a drug-tax stamp. Martin appealed, arguing that these convictions violated constitutional protections against double jeopardy and a Kansas statute prohibiting multiple convictions for the same conduct.The Kansas Supreme Court rejected Martin's argument. It held that possession of methamphetamine and failure to affix a drug-tax stamp were not the same offenses under the Kansas statute, because the former carried a higher penalty than the latter, and because the latter required an element (failure to affix the stamp) not required for the former. Consequently, the legislature had not prohibited multiple punishments for these offenses.The court also held that Martin's convictions did not violate the Double Jeopardy Clauses of the U.S. and Kansas Constitutions. It reasoned that the legislature intended to impose multiple punishments for the offenses because they targeted different conduct (possession of an illegal narcotic versus failure to pay a drug tax) and carried different penalties.On Martin's challenge to the search of his pill bottle, the court found that the search fell within the exception for a search incident to a lawful arrest. The court noted that the officer had a legitimate basis to arrest Martin before the search and that the arrest followed shortly after the search. The court also found that the search of the bottle did not exceed the permissible scope of a search incident to arrest. View "State v. Martin" on Justia Law

In the case before the Supreme Court of the State of Kansas, the appellant, Gabrielle Griffie, appealed her conviction for unlawful assembly under Wichita Municipal Code of Ordinances (W.M.O.) § 5.73.030(1). The conviction was premised on the City of Wichita's disorderly conduct ordinance, W.M.O. § 5.24.010, which defines disorderly conduct as "one or more of the following acts that the person knows or should know will alarm, anger or disturb others or provoke an assault or other breach of the peace", including "using fighting words or engaging in noisy conduct tending to reasonably arouse alarm, anger or resentment in others."Griffie challenged the constitutionality of the "noisy conduct" provision, arguing it was unconstitutionally overbroad under the First Amendment. Both the district court and the Court of Appeals held the provision constitutional. However, the Supreme Court of the State of Kansas disagreed. Applying the substantial overbreadth doctrine used by Kansas courts to adjudicate First Amendment overbreadth challenges, the court concluded the "noisy conduct" provision within W.M.O. § 5.24.010(c) is unconstitutionally overbroad because it prohibits a substantial amount of protected activity in relation to the provision's plainly legitimate sweep.However, the court found that it was not necessary to strike the entire subsection, as there was a satisfactory method of severing the unconstitutional "noisy conduct" provision from the constitutional "fighting words" provision within the same subsection. Accordingly, the court reversed the judgments of the Court of Appeals and the district court. View "City of Wichita v. Griffie" on Justia Law

The Supreme Court of the State of Kansas reversed a lower court's decision, holding that a warrantless traffic stop and subsequent search of a vehicle was unconstitutional under the Fourth Amendment. The case involved Tyler Brandon McDonald, who was stopped by a sheriff's deputy while parked at a public park. The deputy, citing concern for public safety based on a previous murder-suicide in the same area, initiated a public welfare stop. Upon approaching the vehicle, the deputy smelled marijuana, leading to a search of the vehicle and McDonald's subsequent conviction for possession of marijuana and drug paraphernalia.According to the court, the Fourth Amendment protects individuals from unreasonable searches and seizures by the government. A public safety stop is considered a seizure and an exception to the Fourth Amendment's warrant requirement, but it must be justified based on specific and articulable facts that indicate a threat to public safety. Suspicion of criminal activity does not justify a public welfare stop.In this case, the court found that the deputy's reasons for the stop (the late hour, the secluded location, the fact that McDonald was alone, and the deputy's knowledge of past criminal activity in the area) were insufficient to support a public safety stop. The court pointed out that McDonald was parked legally in an open public park, was not in an adverse physical state, and did not appear to be at risk of self-harm. The court concluded that the stop was unconstitutional, reversed the judgment of the lower courts, and reversed McDonald's convictions. View "State v. McDonald" on Justia Law

In the case before the Supreme Court of Kansas, the appellant, Paul Guebara, was convicted of attempted first-degree murder and criminal possession of a weapon by a felon. Guebara had stipulated that he had previously been convicted of "a felony crime" without further detail. The Court of Appeals reversed the criminal-possession conviction, finding that a generic stipulation did not establish that a defendant had been convicted of a felony that would prohibit him from possessing a weapon. The Supreme Court affirmed this decision, explaining that because Kansas' possession-of-a-weapon ban applies only to people who have committed certain felonies, a generic stipulation to "a felony" is insufficient. The court also noted that the district court failed to obtain a jury-trial waiver before accepting Guebara's stipulation, which it deemed to be a constitutional error. However, both errors were found to be harmless beyond a reasonable doubt, as Guebara did not contest his status as a prohibited felon, and the State had conclusive evidence to prove this element. Therefore, the Supreme Court affirmed Guebara's convictions. View "State v. Guebara" on Justia Law

In the case before the Supreme Court of the State of Kansas, the appellant, the State of Kansas, challenged a trial court's decision to suppress the confession of a minor identified as G.O. The trial court had determined that the confession was not voluntary, and therefore inadmissible. The Court of Appeals reversed the trial court's decision, prompting G.O. to appeal to the Supreme Court.The Supreme Court of Kansas considered whether G.O.'s waiver of his Fifth Amendment rights and his confession were voluntary. Under the Fifth Amendment, an individual has the right to remain silent and not incriminate themselves. This right can be waived if the individual voluntarily, knowingly, and intelligently chooses to speak. The court also examined whether G.O.’s Fourteenth Amendment rights were violated, which protect against involuntary confessions being used as evidence.The court found that while G.O. had been read his Miranda rights, the detective conducting the interview had made misleading statements that suggested G.O. was not in trouble and would not be arrested. The detective further suggested that the purpose of the interview was to help G.O.'s stepsister, which the court found was deceptive.The court also took into account G.O.’s age, his mental health issues, his lack of experience with law enforcement, and his educational struggles. The court concluded that these factors, in combination with the detective’s misleading statements, induced G.O. to confess involuntarily.Therefore, the court held that the trial court was correct in suppressing G.O.'s confession. It reversed the Court of Appeals' decision and affirmed the trial court's judgment. View "State v. G.O." on Justia Law

In Kansas, Richard Daniel Showalter was convicted of two counts of first-degree premeditated murder, conspiracy to commit first-degree murder, and aggravated burglary. Showalter appealed his convictions, arguing that the trial court erred by admitting certain autopsy photographs, deposition testimony from an unavailable witness, and statements made by one of his co-conspirators. Regarding the autopsy photographs, Showalter argued they were gruesome and prejudicial, but the court found the photographs were relevant and their probative value outweighed any potential prejudice. As for the deposition testimony, Showalter claimed the court erred in finding the witness was unavailable to testify at trial, but the court ruled that the State made sufficient efforts to establish the witness’s unavailability. Regarding the co-conspirator's statements, Showalter argued they were irrelevant because the State did not prove he was aware of the co-conspirator’s claims, but the court found the statements were relevant to explain the motive and intent behind the murders. Lastly, Showalter argued that the cumulative effect of these alleged errors violated his constitutional right to a fair trial, but the court found no cumulative error as it did not find any individual errors. Accordingly, the court affirmed Showalter’s convictions. View "State v. Showalter" on Justia Law

In the State of Kansas v. Frank Raymond Crudo, the Supreme Court of the State of Kansas affirmed the decisions of the lower courts, ruling against Crudo on all five arguments he presented. Crudo was pulled over for a non-functioning license plate light, and upon approaching the vehicle, officers smelled marijuana, leading to a search of Crudo's truck and attached camper. They found varying amounts of marijuana in different locations, leading to multiple charges against Crudo.Crudo's arguments included: (1) the search of his camper was unconstitutional as it should not be considered part of his vehicle for the purposes of the automobile exception to the Fourth Amendment warrant requirement, (2) the testimony of Lieutenant Ricard at his second trial should have been considered expert testimony and therefore inadmissible due to non-compliance with expert testimony rules, (3) the use of a permissive inference instruction was in error and affected the trial outcome, (4) his second trial for possession with intent to distribute marijuana violated double jeopardy principles, and (5) cumulative error.On the first point, the court ruled that probable cause to search a vehicle under the automobile exception does not need to be "localized" to a specific area of the vehicle and therefore extended to the camper. On the second point, the court held that the district court did not abuse its discretion by admitting Lt. Ricard's testimony as lay opinion testimony. On the third point, the court agreed that the permissive inference instruction was in error, but found it harmless. On the fourth point, the court found that Crudo's convictions for possession and distribution were based on separate acts and thus did not constitute double jeopardy. Lastly, because there was only one error (the permissive inference instruction), the doctrine of cumulative error did not apply. View "State v. Crudo" on Justia Law

In the state of Kansas, a number of non-profit groups, including the League of Women Voters of Kansas and the Kansas Appleseed Center for Law and Justice, challenged a law which made it a felony to engage in conduct that gives the appearance of being an election official or that would cause another person to believe a person is an election official. The non-profits argued that the law was overbroad and unconstitutionally vague, as it could criminalize their voter education and registration activities. They also claimed that the law violated their rights to free speech and association. The district court denied their request for a temporary injunction and the Court of Appeals dismissed the non-profits' claims for lack of standing, arguing that they were not at risk of prosecution under the statute. The Supreme Court of the State of Kansas reversed these decisions, finding that the non-profits did have standing to challenge the law. The Court held that when a law criminalizes speech and does not clearly demonstrate that only constitutionally unprotected speech is being criminalized, the law is unclear enough to confer pre-enforcement standing on a plaintiff challenging the law. The Supreme Court of the State of Kansas vacated the Court of Appeals' decision and remanded the case to the Court of Appeals for further proceedings. View "League of Women Voters of Kansas v. Schwab" on Justia Law

The Supreme Court affirmed the order of the district court reversing its order suppressing evidence found in the car that Defendant was driving on two separate occasions where law enforcement discovered drugs and other contraband, holding that the district court did not abuse its discretion in reversing its suppression order but erred in admitting prior drug use.Defendant was convicted by a jury of two counts of possessing methamphetamine and four counts of possessing drug paraphernalia with intent to use to distribute. The court of appeals reversed and remanded for a new trial on the ground that the district court erroneously allowed the State to introduce evidence relating to Defendant's prior convictions for similar crimes. The Supreme Court affirmed, holding (1) the district court erred in admitting prior drug crime evidence, and the error was not harmless; and (2) the district court did not abuse its discretion in granting the State's motion to reconsider its erroneous suppression ruling. View "State v. Campbell" on Justia Law