Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Defendant's motions filed under Kan. Stat. Ann. 60-1507 and Kan. Stat. Ann. 22-3504, holding that Defendant's section 60-1507 motion was untimely and successive and that Defendant's sentence was not illegal.In 2003, Defendant was convicted by a jury of first-degree murder and sentenced to a hard fifty life sentence. Since his conviction, Defendant filed multiple collateral attacks on his sentence and conviction, all of which were unsuccessful. In the motions at issue on appeal, Defendant alleged that his sentence was unconstitutional under Apprendi v. New Jersey, 530 U.S. 466 (2000) and that this Court's failure to correct his sentence violated Kan. Stat. Ann. 21-6628(c). The district court denied both motions. The Supreme Court affirmed, holding that the district court did not err in denying the motions. View "Drennan v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's pro se motion to correct an illegal sentence, holding that the district court did not err in summarily denying Defendant's motion.A jury convicted Defendant of aggravated burglary, aggravated kidnapping, rape, and two counts of aggravated sodomy. Defendant later filed a pro se motion to correct an illegal sentence under Kan. Stat. Ann. 22-3504, arguing that his sentence was illegal because he was denied his statutory right to a speedy trial and his right to allocution at sentencing. The district court denied the motion without holding an evidentiary hearing. The Supreme Court affirmed, holding that neither of Defendant's claims was properly before the court in a motion to correct an illegal sentence. View "State v. Mitchell" on Justia Law

The Supreme Court denied an amended petition in mandamus and quo warranto filed by the Kansas Attorney General, on behalf of Wyandotte County Election Commissioner Scott Schwab and Wyandotte County Election Commissioner Michael Abbott, seeking dismissal of three lawsuits pending before Wyandotte County District Court Judge Bill Klapper and Douglas County District Judge Mark Simpson, holding that Petitioners' claims did not lie in either mandamus or quo warranto.Two lawsuits at issue were filed in the Wyandotte County District Court and asked the district court to rule that congressional reapportionment map known as "Ad Astra 2" and contained in Senate Bill 355 violates the Kansas Constitution. The suits named as defendants Schwab and Abbott. The third lawsuit based on these same facts was filed in Douglas County District Court against Shwab. The Supreme Court denied relief, holding that Petitioners' claims did not lie in either mandamus or quo warranto. View "Schwab v. Klapper " on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and aggravated robbery and his resulting sentences, holding that there was no reversible error.Defendant was found guilty by a jury of committing first-degree premeditated murder and aggravated robbery when he was fifteen years old. Defendant was sentenced life imprisonment for the murder conviction and a consecutive sixty-one months' term of imprisonment for the robbery conviction. The Supreme Court affirmed, holding (1) the district court did not err by not giving an instruction on voluntary manslaughter-heat of passion; (2) Defendant failed to show that the prosecutor erred; and (3) Defendant's sentence did not violate the Eighth Amendment's prohibition of cruel and unusual punishment under the principles announced in Miller v. Alabama, 567 U.S. 460 (2012). View "State v. Gulley" on Justia Law

The Supreme Court reversed the panel of the court of appeals that applied the 2018 amendments to Kan. Stat. Ann. 8-1567, the driving under the influence (DUI) statute, to Defendant, who committed a DUI before, but was sentenced after, the amendments came into effect, holding that the court of appeals erred.The Supreme Court clarified the general rule established in State v. Reese, 333 P.3d 149 (Kan. 2014), that courts should apply the DUI sentencing provisions in effect at the time of sentencing but holding that a sentencing court should apply the version of section 8-1567 in effect at the time of sentencing unless the Legislature amended the statutory provisions after the offense was committed and that amendment increases the defendant's penalty. The Court remanded the matter to the district court for resentencing under the sentencing provisions in effect when Defendant committed the DUI, holding that applying the 2018 amendments to Defendant at sentencing would increase his punishment in violation of the Ex Post Facto Clause. View "State v. Patton" on Justia Law

The Supreme Court affirmed Defendant's death sentence imposed in connection with his conviction for capital murder, holding that Defendant was not entitled to relief on the penalty phase issues before the Court on remand from the United States Supreme Court in Kansas v. Carr, 477 U.S. 108 (2016).In its previous decision, the Supreme Court affirmed Defendant's conviction but vacated his death sentence, concluding that the trial court violated Defendant's Eighth Amendment right to an individualized sentencing determination by refusing to sever the trial's penalty phase from that of his codefendant brother. On remand, the Supreme Court affirmed Defendant's death sentence, holding (1) the record supported the findings that one or more aggravating circumstances existed and that any mitigating circumstances were insufficient to outweigh the aggravating circumstances; and (2) Defendant received a fair trial. View "State v. Carr" on Justia Law

The Supreme Court affirmed Defendant's sentence of death imposed in connection with his conviction for capital murder, holding that the sentence was not "imposed under the influence of passion, prejudice or any other arbitrary factor." See Kan. Stat. Ann. 21-6619(c)(1).Defendant was convicted of capital murder and sentenced to death. The Supreme Court affirmed the convictions but vacated the death sentencing, holding that the failure to sever the penalty phase violated Defendant's right to an individualized sentencing determination under the Eighth Amendment. However, in Kansas v. Carr, 477 U.S. 108 (2016), the United States Supreme Court held that the trial court's failure to Defendant's penalty phase did not implicate either the Eighth Amendment or the Due Process Clause. On remand, the Supreme Court addressed penalty phase issues that remained unresolved. The Court then affirmed Defendant's sentence, holding that Defendant received a fair trial and that any mitigating circumstances were insufficient to outweigh the aggravating circumstances. View "State v. Carr" on Justia Law

The Supreme Court affirmed Defendant's conviction for possession of methamphetamine for insufficient evidence, holding that the evidence was sufficient to support the conviction and that Defendant could not challenge the underlying search of the vehicle in which he was a passenger.On appeal, the court of appeals reversed Defendant's conviction of methamphetamine possession for insufficient evidence based on the parties' stipulation of facts. The Supreme Court reversed, holding that the court of appeals (1) erred in concluding that Defendant's conviction was not supported by sufficient evidence; and (2) correctly concluded that Defendant's status as a passenger did not confer standing for purposes of the Fourth Amendment to challenge the search of the car. View "State v. Scheuerman" on Justia Law

The Supreme Court reversed the portion of the district court's judgment declaring 2021 Senate Bill 40 invalid and unenforceable based on certain infirmities the court observed, holding that the district court erred by ignoring the constitutional avoidance doctrine and failing to abide by it.This case arose from a dispute regarding public school policies mandating face masks during the COVID-19 pandemic. After the Legislature passed S.B. 40 imposing substantive limits on COVID-19 mitigation measures adopted by other governmental entities Plaintiffs sued the Shawnee Mission School District challenging the district's mask policy. Plaintiffs asserted S.B. 40 as the only legal authority for their lawsuit. The district court dismissed the claims as moot and then ruled that S.B. 40 was unenforceable because it violated both due process and separation of powers. The Supreme Court reversed, holding that the district court erred in its analytical diversion into S.B. 40's constitutionality. View "Butler v. Shawnee Mission School District Board of Education" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, holding that the errors committed during Defendant's trial did not affect the jury's verdict.Specifically, the Supreme Court held (1) there was no error in the admission of an autopsy photograph; (2) the prosecutor erred in closing argument by repeatedly use the phrase "we know" before discussing controverted facts, but the error was harmless; (3) presuming that the district court erred in not instructing the jury on the limited purpose for which the judge admitted some evidence, the error did not affect the verdict; (4) there was no error when the district court listed the jury's choice of finding Defendant guilty before listing the option of not guilty on the verdict form; and (5) the cumulative errors in this case did not affect the outcome. View "State v. Alfaro-Valleda" on Justia Law