Justia Constitutional Law Opinion Summaries

After a bench trial on stipulated facts, Defendant was convicted of first-degree murder, aggravated robbery, aggravated kidnapping, aggravated assault, and criminal possession of a firearm. The Supreme Court affirmed on direct appeal. Thereafter, Defendant filed a pro se Kan. Stat. Ann. 60-1507 motion collaterally attacking his conviction and sentence, alleging that appointed counsel had a conflict of interest and provided deficient representation. The district court denied the motion. The court of appeals affirmed, concluding that Defendant was barred by res juicata from relitigating his claims and that his newly asserted claim of ineffective assistance of counsel failed on the merits. The Supreme Court affirmed, holding (1) the court of appeals erred as a matter of law when it determined that Defendant’s ineffective assistance of counsel claim was barred by the doctrine of res judicata because it was not litigated on direct appeal; but (2) the court of appeals correctly held that Defendant’s claim failed on the merits because he could not demonstrate any prejudice. View "Bogguess v. State" on Justia Law

Defendant was found guilty by a jury of first-degree murder, aggravated burglary, and theft. The trial court sentenced Defendant to a hard fifty life sentence for murder. The Supreme Court affirmed the convictions and sentences, holding (1) the district court did not commit reversible error when it excluded evidence of the victim’s other computer dating contacts; (2) the prosecutor did not engage in error during closing argument; (3) the evidence was sufficient to prove the conviction for aggravated burglary; (4) the district court’s limitation of voir dire questioning did not deprive Defendant of his constitutional right to a fair trial; and (5) the State provided Defendant with constitutionally satisfactory notice that it would seek a hard fifty sentence. View "State v. Robinson" on Justia Law

A jury convicted Defendant of two alternative counts of capital murder based on either the rape or the kidnapping of eight-year-old A.I., an alternative count of premeditated first-degree murder, and rape. The Supreme Court affirmed the district court’s judgment with the exception of Defendant’s rape conviction, which the court reversed. The court held (1) there was sufficient evidence to support the jury’s determination that Defendant premeditated A.I.’s killing; (2) prosecutorial error in closing argument did not require reversal; (3) the district court did not err in denying Defendant’s motion to suppress his confession; (4) there was no error in the omission of additional unanimity language in the jury instructions; and (5) because rape is an element of Defendant’s conviction for capital murder, he is punished for it to the extent the capital conviction stands. View "State v. Davis" on Justia Law

After a jury trial, Defendant was convicted of distribution of methamphetamine. Defendant appealed, arguing that an audio recording of a nontestifying informant’s statements were improperly admitted into evidence because the informant’s statements were testimonial and thus violated Defendant’s right to confront witnesses under the Sixth Amendment and Crawford v. Washington. The Court of Appeals affirmed, concluding that, under the circumstances, the informant’s statements were not testimonial in nature. The Supreme Court affirmed, holding that the informant’s statements qualified as testimonial, but the error in admitting the informant’s testimonial evidence was harmless. View "State v. Williams" on Justia Law

Adam Pener was the trustee and personal representative of a trust and estate that owned property condemned by the Kansas Department of Transportation for a highway improvement project. The district court found the damages from the taking were $295,702. Defendant appealed, arguing (1) the district court gave insufficient weight to the replacement value for a fence and to a comparable sale when it calculated the property’s value, and (2) the district court should have awarded him attorney fees and expenses. The Supreme Court affirmed, holding (1) the compensation award was supported by substantial evidence; and (2) the district court did not err in denying attorney fees and expenses. View "Pener v. King" on Justia Law

Defendant was charged with driving under the influence and unlawful exhibition of speed. Defendant moved to suppress the evidence of his driving under the influence, arguing that the officer lacked reasonable suspicion to conduct the traffic stop. The district court denied the motion and convicted Defendant. The court of appeals reversed, concluding (1) Kan. Stat. Ann. 8-1565, which prohibits an unlawful “exhibition of speed or acceleration,” was unconstitutionally vague and indefinite, and the good faith exception was inapplicable; and (2) alternatively, the officer lacked reasonable suspicion to conduct a traffic stop. The Supreme Court (1) affirmed the court of appeals’ decision that the district court erroneously denied the motion to suppress on the grounds that reasonable suspicion did not exist to conduct the traffic stop; (2) summarily vacated the court of appeals’ determination that section 8-1565 is unconstitutionally vague as applied to Defendant; and (3) reversed Defendant’s convictions and vacated his sentences and fines. View "State v. Sharp" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, aggravated kidnapping, and aggravated robbery. The district court imposed a hard fifty sentence for first-degree murder under Kan. Stat. Ann. 21-4635 without fact-finding by the jury. The Supreme Court affirmed Defendant’s convictions but vacated his hard fifty sentence, holding that Defendant was sentenced in violation of the Sixth Amendment because the district court, rather than the jury, found the existence of aggravating factors by a preponderance of the evidence, rather than beyond a reasonable doubt, in violation of Alleyne v. United States. Remanded for resentencing. View "State v. Mattox" on Justia Law

After a jury-waived trial, Defendant was convicted of criminal possession of a firearm by a convicted felon. The court of appeals affirmed. Defendant appealed, raising three arguments. The Supreme Court affirmed, holding (1) with regarding to Defendant’s first and third issues, the court of appeals reached the correct conclusions; and (2) Defendant’s argument that his firearm should have been suppressed as evidence because it was obtained through an illegal search of his car was without merit because the search of Defendant’s car was legal under the exigent circumstances plus probable clause exception to the search warrant requirement. View "State v. Howard" on Justia Law

In 2010, Plaintiffs filed an action claiming that the State violated Kan. Const. art. VI, 6(b) by inequitably and inadequately funding K-12 public education. A three-judge panel determined that, through the School District Finance and Quality Performance Act (SDFQPA), the State had inequitably and inadequately funded education in violation of Article 6. On appeal, the Supreme Court affirmed the panel on equity but determined that the panel did not apply the correct standard in concluding that the State violated the adequacy component. On remand, the panel declared the financing under the SDFQPA and the subsequently enacted Classroom Learning Assuring Student Success Act (CLASS), which replaced the SDFQPA, to be constitutionally inadequate. The Supreme Court affirmed, holding that the panel correctly found that the financing system is constitutionally inadequate. As a remedy, the Court stayed the issuance of today’s mandate and ordered that, by June 30, 2017, the State must demonstrate that any K-12 public education financing system the legislature enacts is capable of meeting the adequacy requirements of Article 6. Otherwise, a lifting of the stay of today’s mandate will mean that the State’s education financing system is constitutionally invalid and therefore void. View "Gannon v. State" on Justia Law

The one-subject rule in Article 2, Section 16 of the Kansas Constitution provides that “[n]o bill shall contain more than one subject, except appropriation bills an bills for revision or codification of statutes.” At issue in this case was whether 2014 Senate Substitute for House Bill No. 2506 violates the one-subject rule. Kansas National Education Association (KNEA) argued that the bill violates the one-subject rule because it contains both appropriations and substantive general legislation. The district court dismissed the complaint, concluding that KNEA failed to state a claim as a matter of law because H.B. 2506 did not violate Article 2, Section 16. The Supreme Court affirmed, holding (1) KNEA had standing to bring this lawsuit, and its claim is ripe; (2) Article 2, Section 16 does not forbid combining appropriations and general legislation into one bill, provided that all provisions of that bill address the same subject; and (3) H.B. 2506’s provisions relate to one subject. View "Kansas National Education Ass’n v. State" on Justia Law