Justia Constitutional Law Opinion Summaries

The Supreme Court reversed the decision of the court of appeals reversing the decision of the district court dismissing as untimely and successive Defendant's motion filed under Kan. Stat. Ann. 60-1507, holding that the court was correct to dismiss the motion as untimely.Defendant was convicted in 2000 of premeditated murder, aggravated robbery, and aggravated burglary for acts he committed when he was fourteen years old. The district court sentenced Defendant to two concurrent life sentences without the possibility of parole for fifty years. Defendant later filed his section 60-1507 motion, arguing that the scheme under which he was sentenced violated the Eighth Amendment. The district court dismissed the motion. The court of appeals reversed, concluding that Defendant's motion was subject to an exception to the prohibition on successive motions. The Supreme Court reversed, holding that Defendant's sentencing scheme satisfied the constitutional requirements of Miller v. Alabama, 567 U.S. 460 (2012), and therefore, it was unnecessary to consider Defendant's motion to prevent manifest injustice. View "Williams v. State" on Justia Law

The Supreme Court affirmed Defendant's sentence of life imprisonment with no chance of parole for fifty years but vacated the district court's order imposing lifetime postrelease supervision and electronic monitoring as a condition of parole, holding that those components of Defendant's sentence were illegal.Defendant pleaded no contest to premeditated first-degree murder. The district court denied Defendant's request to depart from his presumptive hard fifty sentence and to instead sentence him to a hard twenty-five sentence. The court then imposed lifetime postrelease supervision and electronic monitoring as a condition of his parole. The Supreme Court affirmed Defendant's hard fifty sentence, holding that the district court (1) did not err in denying Defendant's departure motion; but (2) lacked authority to impose lifetime postrelease or electronic monitoring parole conditions. View "State v. Boswell" on Justia Law

The Supreme Court affirmed Defendant's convictions and restitution order, holding that any error did not require reversal of the convictions.Defendant was convicted of first-degree felony murder and aggravated burglary. The district judge sentenced Defendant to a hard twenty-five life sentence plus forty-three months and ordered him to pay $7,470 in restitution. The Supreme Court affirmed, holding (1) the district judge did not abuse its discretion in admitting two sets of statements; (2) the judge did not commit reversible error by twice denying Defendant's requests for a mistrial; (3) the aggravated burglary instruction was not clearly erroneous; (4) the prosecutor committed harmless error during closing arguments; (5) the cumulative effect of any errors did not deny Defendant a fair trial; and (6) Defendant's original restitution judgment was constitutionally firm. View "State v. Owens" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the restitution ordered against Petitioner by the district court, holding that the restitution did not violate Petitioner's right to a jury under both the Sixth Amendment of the United States Constitution and section 5 of the Kansas Constitution Bill of Rights.Defendant pled guilty to one count of conspiracy to commit burglary for providing the car which her boyfriend used to burglarize two houses. The boyfriend paid Defendant $200 when he returned the car. The district court ordered that Defendant and her codefendants pay the full amount of the State's requested restitution, $33,249, jointly and severally. The court of appeals affirmed. The Supreme Court affirmed, holding (1) criminal restitution does not violate the Sixth Amendment to the United States Constitution; and (2) the current structure of criminal restitution violates section 5 of the Kansas Constitution Bill of Rights but is remedied by severance. View "State v. Arnett" on Justia Law

The Supreme Court reversed Defendant's convictions of battery against a law enforcement officer and intentional criminal threat, holding that the cumulative effect of five errors in Defendant's trial affected the trial's outcome.After a jury trial, Defendant was convicted of possession of marijuana, battery against a law enforcement officer, and intentional criminal threat. The court of appeals reversed the marijuana conviction and ordered a new trial on the marijuana charge and identified four other trial errors related to Defendant's remaining convictions but determined that, individually and collectively, they were harmless. The Supreme Court reversed the court of appeals and reversed Defendant's two remaining convictions, holding that the cumulative effect of five errors made during trial affected the trial's outcome. The Court remanded the case for a new trial. View "State v. Taylor" on Justia Law

The Supreme Court reversed Defendant's conviction of two counts of rape of a child under fourteen years of age, holding that Defendant's counsel was ineffective.A jury convicted Defendant of two counts of rape of a child under fourteen years of age for her actions as a middle school counselor in allegedly engaging in sex acts with a student. The court of appeals affirmed. The Supreme Court reversed the court of appeals' holding that Defendant's intent was irrelevant in this case and remanded the case to the district court for a Van Cleave hearing. The district court concluded that trial counsel had not been ineffective. The Supreme Court reversed and remanded the case for a new trial, holding (1) the absence of an instruction permitting the jury to apply Defendant's defense was prejudicial; and (2) there is no mental culpability requirement for rape of a child under fourteen. View "State v. Dinkel" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals finding that lifetime registration requirements under the Kansas Offender Registration Act (KORA), Kan. Stat. Ann. 22-4906(c), were not punishment as applied N.R. and therefore did not trigger any constitutional provisions identified by N.R., holding that there was no error.N.R. pled guilty to rape and was adjudicated a juvenile offender. The gestate judge ordered N.R. to register as a sex offender for five years under KORA. Just before N.R.'s registration period was about to expire, the legislature amended KORA. As a result, N.R. was required to register for life. Later, the State charged N.R. for failing to register. N.R. filed a motion to dismiss, arguing that KORA's mandatory lifetime registration requirements for juvenile sex offenders violates the federal and state constitutional provisions against cruel and unusual punishment and the federal constitutional provision against ex post facto punishment. The district court found Defendant guilty. The Supreme Court affirmed, holding that KORA's mandatory lifetime registration requirements as applied to N.R. are not punishment and therefore do not violate the federal Ex Post Facto Clause or the prohibition against cruel and unusual punishment under the Kansas and United States Constitutions. View "State v. N.R." on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated criminal sodomy and the requirement that he register as a sex offender for life under the Kansas Offender Registration Act (KORA), Kan. Stat. Ann. 22-4906(c), holding that there was no error in the proceedings below.On appeal, Defendant argued that retroactive application of KORA violates the federal constitutional prohibition against ex post facto punishment, constituted cruel and unusual punishment, and infringed on his right to due process. The appellate court affirmed. The Supreme Court affirmed, holding (1) Defendant's due process and cruel and unusual punishment arguments were waived and abandoned; and (2) KORA registration requirements are not punitive in purpose or effect, and therefore, retroactive application of KORA provisions to Defendant did not violate the Ex Post Facto Clause of the United States Constitution. View "State v. Davidson" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of rape, two counts of aggravated criminal sodomy, and one count of aggravated intimidation of a victim, holding that the district court did not err when it permitted the father of the victim (Father) to invoke his Fifth Amendment privilege against self-incrimination.Father had previously been convicted of sexual abuse of the victim. During trial, the district court allowed Father to invoke his Fifth Amendment privilege against self-incrimination and excused him from the trial. The court of appeals reversed Defendant's convictions, holding that the district court erred when it permitted Father to invoke the Fifth Amendment privilege and that the error was not harmless. The Supreme Court reversed, holding that the district court did not err in excluding Father's testimony as evidence. View "State v. Contreras" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to withdraw his plea of guilty to two counts of felony first-degree murder, holding that Defendant failed to prove manifest injustice in the circumstances of entering his guilty plea.Defendant pled guilty two two counts of felony first-degree murder, and the court sentenced him to two consecutive hard twenty-five life sentences. Defendant then filed his pro se motion seeking relief on a wide variety of grounds. The trial court denied relief. The Supreme Court affirmed, holding that any failures on the part of counsel to inform Defendant that compulsion is a defense to felony murder did not rise to the level of manifest injustice that would require a court to give him leave to withdraw his plea. View "State v. Hutto" on Justia Law