Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court reversing Defendant's conviction of aggravated battery, rape, and aggravated kidnapping on the grounds that a conflict of interest existed between Defendant and his counsel that adversely affected the representation.In his Kan. Stat. Ann. 60-1507 motion for relief from his convictions Defendant argued that his counsel had a personal and financial conflict of interest that adversely affected his performance in Defendant's case. The district court agreed and set aside Defendant's convictions without determining whether prejudice resulted from the conflict of interest. The Supreme Court affirmed, holding that Defendant's convictions must be reversed based on the financial conflict of interest of his trial counsel. View "Ellie v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for possession of marijuana, methamphetamine, and drug paraphernalia, holding that the trial court erred in admitting evidence that a syringe was found by police during a search that violated Defendant's Fourth Amendment rights but that the error was harmless.On appeal, the State conceded that the district court should have granted Defendant's motion to suppress on the syringe, admitting that the search incident to arrest exception for a warrantless search did not apply to this particular search. The court of appeals affirmed, accepting the State's concession that the syringe discovery was the product of an illegal search but without determining whether the evidence was harmless beyond a reasonable doubt. The Supreme Court affirmed, holding the court's admission of the syringe evidence was harmless beyond a reasonable doubt. View "State v. Thornton" on Justia Law

The Supreme Court reversed Defendant's conviction for distribution of a controlled substance and affirmed Defendant's remaining convictions, holding that there was insufficient evidence to support the distribution conviction.A jury found Defendant guilty of felony murder, distribution of a controlled substance, attempted aggravated robbery, criminal possession of a weapon, attempted murder in the second degree, criminal discharge of a firearm, aggravated battery, and aggravated burglary. The Supreme Court reversed one conviction and otherwise affirmed, holding (1) the district court did not abuse its discretion in consolidating Defendant's cases for trial; (2) the evidence was insufficient to convict Defendant of distribution; and (3) the jury instructions on Defendant's aggravated robbery, felony murder, and criminal possession of a firearm charges were not erroneous. View "State v. Crosby" on Justia Law

In this workers compensation case, the Supreme Court reversed the judgment of the court of appeals holding that Kan. Stat. Ann. 44-510e(a)(2)(B) was unconstitutional on its face, holding that the statute is constitutional.Appellant was injured during his employment and filed for workers compensation benefits. A doctor rated Appellant's permanent partial impairment using the Sixth Edition of the American Medical Association Guides, as adopted by the Kansas Workers Compensation Act. See section 44-510e(a)(2)(B). The court of appeals reversed, holding that the statute's use of the Sixth Edition was unconstitutional on its face because it changed the essential legal standard for determining functional impairment. The Supreme Court reversed after construing the ambiguous statutory language to avoid the constitutional question, holding that the language of section 44-510e(a)(2)(B) referencing the Sixth Edition can reasonably be interpreted as a guideline rather than a mandate. View "Johnson v. U.S. Food Service" on Justia Law

The Supreme Court affirmed the Defendant's convictions of premeditated first-degree murder and two counts of cruelty to animals, holding that there was no error in the proceedings below.Specifically, the Supreme Court held that the district court (1) erred when it included additional information in the standard premeditation Pattern Instructions for Kansas instruction; (2) did not err when it failed to instruct the jury on heat of passion voluntary manslaughter; (3) certain testimony did not violate Defendant's rights under the Confrontation Clause; and (4) because there was no error, cumulative error did not deny Defendant a fair trial. View "State v. Stafford" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree murder, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) Defendant failed to preserve his claim that the district court erred when it refused to grant a mistrial after a witness claimed to have "double memories" and gave premeditation jury instructions; (2) the district court did not err when it included additional language in the general Pattern Instructions for Kansas defining premeditation; and (3) premeditated first-degree murder and intentional second-degree murder are not identical offenses, and Kan. Stat. Ann. 21-5402(a)(1) is not unconstitutionally vague. View "State v. Stanley" on Justia Law

The Supreme Court affirmed Defendant's convictions for two counts of first-degree murder, two counts of criminal discharge of a firearm, and one count of criminal possession of a firearm, holding that there was no error in the proceedings above.On appeal, Defendant argued that the voir dire proceedings were closed to his family members and that not providing space for spectators violated his Sixth Amendment right to a public trial. The Supreme Court affirmed, holding (1) the trial court properly determined that the voir dire proceeding was open was reasonable and supported by substantial competent evidence; (2) the court did not abuse its discretion in deciding to admit certain testimony; and (3) Defendant's remaining allegations of error were not properly before the Supreme Court. View "State v. Carter" on Justia Law

The Supreme Court affirmed the decisions of the court of appeals and the district court allowing consideration of Defendant's blood test results obtained under the implied consent statute, holding that the good faith exception to the exclusionary rule allowed the district court to consider the results of Defendant's blood test.Defendant filed a motion to suppress the blood test results as unconstitutional. The district court denied the motion and found Defendant guilty of driving under the influence. The court of appeals affirmed, holding that the good faith exception applied to the results of Defendant's blood test. The Supreme Court affirmed, holding (1) Defendant offered no persuasive reason for this Court to abandon its decision in State v. Perkins, 449 P.3d 756 (Kan. 2019), in which the Court held that the good-faith exception applies to breath tests for blood alcohol content collected under the unconstitutional implied consent statute; and (2) the court of appeals did not err in applying the good faith exception, and the district court did not err in holding that Defendant's blood test result was admissible. View "State v. Heim" on Justia Law

The Supreme Court affirmed the decisions of the court of appeals and the district court allowing consideration of Defendant's blood test results, which presumptively showed that Defendant was guilty of driving under the influence, holding that Defendant did not persuade the Court to abandon its recent decision in State v. Perkins, 449 P.3d 756 (Kan. 2019).On appeal, Defendant argued that his warrantless blood test obtained under the implied consent statute was unconstitutional based either on consent or as a search incident to arrest. The court of appeals affirmed, ruling that the district court properly considered the results of Defendant's blood test under the good faith exception to the exclusionary rule. The Supreme Court affirmed, holding (1) Defendant offered no persuasive reason for this Court to abandon Perkins; and (2) the court of appeals did not err in applying the good faith exception, and the district court did not err in holding that Defendant's blood test result was admissible. View "City of Kingman v. Ary" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals reversing the judgment of the district court granting Defendant's motion to suppress all evidence seized as a result of a warrantless search of his apartment, holding that Kansas law does not foreclose consent through nonverbal conduct.Defendant was charged with several drug-related offenses. Defendant filed a motion to suppress, arguing that he did not validly consent to the warrantless search of his apartment because he did not verbally agree to let the officers enter. The district court granted the motion. The court of appeals reversed, finding that Defendant had affirmatively communicated to the officers that they could enter his apartment. At issue on appeal was whether nonverbal conduct can establish valid consent. The Supreme Court held that it can, holding (1) an individual may express valid consent through words, acts, or conduct, and an individual's nonverbal conduct can be relevant in determining whether this standard has been met; and (2) the matter must be remanded for a new hearing under the appropriate legal standards. View "State v. Daino" on Justia Law