Justia Constitutional Law Opinion Summaries

Articles Posted in Kansas Supreme Court
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The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, selling sexual relations, and two counts of felony theft, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant argued that the district court erred in determining that her incriminating statements made to law enforcement confessing to the murder were made voluntarily. Among other things, Defendant contended that sleep deprivation and drug use tainted her interview and that her confinement in the interview room was coercive. The Supreme Court affirmed, holding (1) the district court correctly held that Defendant's statements were freely, voluntarily, and knowingly given and admissible at trial; and (2) ample evidence supported the jury's finding of premeditation. View "State v. Spencer" on Justia Law

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The Supreme Court affirmed Defendant's conviction of two counts of possessing firearms by a felon and one count of possessing methamphetamine with intent to distribute but reversed his conviction of one count of driving with a suspended license, holding that the evidence did not support the suspended license conviction.Specifically, the Supreme Court held (1) the district court did not err in finding that Defendant's statements during an interrogation were voluntary and admissible at trial; (2) the district court's failure to obtain a jury trial waiver before an elemental stipulation was not structural, and the error did not affect the trial's outcome; (3) the lower courts did not err in holding that trial counsel was not ineffective in pursuing a guilt-based defense; (4) there was no clear error in the jury instructions; and (5) the State failed to present evidence of a necessary element of the crime of driving while Defendant's license was suspended. View "State v. Bentley" on Justia Law

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The Supreme Court affirmed in part and reversed in part Defendant's convictions, holding that the prosecutor committed prosecutorial error during closing argument, and the State failed to carry its burden to prove the error was harmless to those convictions that required the State to prove Defendant's intent to distribute.The Supreme Court affirmed Defendant's convictions for driving while suspended and aggravated child endangerment but reversed his conviction for possessing methamphetamine with intent to distribute, holding (1) this Court declines to reach the merits of Defendant's instructional challenge and his constitutional challenge to Kan. Stat. Ann. 21-5705(e)(2); and (2) the prosecutor erred by mischaracterizing the permissive inference jury instruction during closing argument, and the State failed to carry its burden to prove this error was harmless. View "State v. Slusser" on Justia Law

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The Supreme Court affirmed Defendant's conviction for the first-degree premediated murder of her estranged husband, holding that Defendant was not entitled to reversal on her claims of error.Specifically, the Supreme Court held (1) the district court did not abuse its discretion or violate Defendant's right to confrontation under the Sixth Amendment by placing limits on cross-examination; (2) the district court did not err by denying Defendant's motion for judgment of acquittal at the close of the State's evidence because the State presented sufficient evidence to establish a prima facie case of first-degree premeditated murder against Defendant; and (3) sufficient evidence supported Defendant's conviction for first-degree premeditated murder. View "State v. Frantz " on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Appellant's motion to modify his sentence under Kan. Stat. Ann. 21-6628(c), which requires courts to modify sentences if certain sentencing provisions are found to be unconstitutional, holding that Appellant was not entitled to a sentencing modification.In 1999, Appellant was convicted of first-degree premeditated murder and sentenced to a hard forty sentence. After a retrial in 2005, Appellant was again convicted of premeditated first-degree murder. Before sentencing, Appellant filed a motion arguing that the hard forty sentencing scheme violated his Sixth Amendment right to a jury trial. The sentencing court denied the motion and again imposed a hard forty life sentence. In 2016, after the Supreme Court decided State v. Soto, 322 P.3d 344 (Kan. 2014), Appellant filed a motion for a sentencing modification under section 21-6628(c). The district court denied the motion. The Supreme Court affirmed, holding that the district court correctly denied the motion. View "State v. Albright" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for violating the Kansas Offender Registration Act (KORA) by failing to register, holding that the legislature's decision to make the crime of failure to register a strict liability felony did not violate Defendant's substantive due process rights.After a jury trial, Defendant was found guilty of violating KORA under Kan. Stat. Ann. 22-4903(a) and (c)(1)(A) based on his failure to report in person during the month of November 2017. On appeal, Defendant argued that the strict liability character of the offense was unconstitutional. The court of appeals disagreed and affirmed. The Supreme Court affirmed, holding that Defendant failed to show that Kan. Stat. Ann. 21-5203(e)'s strict liability criminalization of KORA registration violations did not violate Defendant's substantive due process rights. View "State v. Genson" on Justia Law

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The Supreme Court affirmed the judgment of the district court dismissing two of the charges against Appellant, which arose under Wichita Municipal Ordinances (W.M.O.) 3.06.030.A and 3.30.030.A, holding that W.M.O. 3.06.030.A is overbroad.The district court fully vacated Appellant's convictions, finding W.M.O. 3.06.030.A unconstitutionally overbroad because it intrudes on several examples of "Constitutionally protected behaviors." The court of appeals reversed the lower court's conclusion that W.M.O. 3.06.030.A was unconstitutionally overbroad and sua sponte reversed the dismal of the charge arising under W.M.O. 3.30.030.A. The Supreme Court reversed in part, holding (1) W.M.O. 3.06.030.A is unconstitutionally overbroad; and (2) the court of appeals erred by sua sponte dismissing the second municipal charge. View "City of Wichita v. Trotter" on Justia Law

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The Supreme Court affirmed Defendant's conviction of aggravated indecent liberties with a child, holding that Defendant was not entitled to relief on any of his claims of error.Specifically, the Supreme Court held (1) the district court's exclusion of polygraph evidence did not violate Defendant's constitutional right to present a complete defense; (2) the district court did not abuse its discretion by allowing the State to amend the information; (3) although the admission of Defendant's videotaped confession to a previous offense may have been inflammatory, any error was harmless; and (4) cumulative error did not deny Defendant a fair trial. View "State v. White" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to suppress evidence obtained during a search that led to the State charging Defendant with possession of drugs and drug paraphernalia with the intent to distribute, holding that the district court properly denied the suppression motion.This appeal arose after police officers detained Defendant while he sat in a minivan in an alleyway. Defendant filed a motion to suppress the evidence obtained during the search, arguing that the seizure of the minivan violated his constitutional rights. The district court concluded that the detention was reasonable and justified under the public safety exception to the warrant requirement. The court of appeals affirmed. The Supreme Court affirmed, holding that the seizure of the minivan was reasonable under the Fourth Amendment and section 15 of the Kansas Constitution Bill of Rights. View "State v. Bates" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the decision of the trial court judge dismissing this case with prejudice after suppressing evidence as a discovery sanction, holding that, under the circumstances, the district court did not abuse its discretion in dismissing the case with prejudice.Defendant was charged with drug-related offenses. The district court ultimately dismissed the charges with prejudice after suppressing certain evidence as a discovery sanction. The court of appeals reversed and remanded hte case, concluding that the district court abused its discretion by dismissing the case with prejudice for a discovery failure. The Supreme Court reversed, holding (1) the judge infringed on the prosecutor's discretion by not leaving to the prosecutor the decision of whether to proceed to trial; and (2) the error was harmless. View "State v. Mulleneaux" on Justia Law