Justia Civil Rights Opinion Summaries

In 2015, Brennan R. Trass was charged with first-degree felony murder and criminal possession of a firearm after killing Jose Morales during a drug deal. Trass admitted to the shooting, claiming self-defense. Before trial, the district court appointed multiple attorneys for Trass due to conflicts, causing significant delays. Two weeks before the trial in 2019, the court allowed Trass' attorneys to withdraw due to a conflict and ordered Trass to represent himself with standby counsel. During the trial, Trass was removed from the courtroom for refusing to participate, and his standby counsel took over. The jury convicted Trass.The Reno District Court initially handled the case, where Trass faced multiple attorney changes and delays. Trass filed a direct appeal, and the Kansas Supreme Court remanded the case to the district court to determine the feasibility of a retrospective competency hearing. The district court found Trass competent before and during his 2019 trial. Trass raised several issues on appeal, including violations of his right to counsel, speedy trial rights, and sufficiency of evidence.The Kansas Supreme Court reviewed the case and found that the district court violated Trass' Sixth Amendment right to counsel by forcing him to represent himself without proper advisories or warnings about the dangers of self-representation. The court concluded that Trass did not waive his right to counsel knowingly and intelligently, nor did he forfeit it through egregious misconduct. The violation of Trass' right to counsel constituted structural error, requiring automatic reversal of his convictions. The court also found no violation of Trass' statutory right to a speedy trial and sufficient evidence to support his felony-murder conviction. The case was reversed and remanded for a new trial before a different judge. View "State v. Trass" on Justia Law

The case revolves around William P. Spangler, who was initially convicted of second-degree murder for his role in the shooting death of Faustino Martinez. After serving a prison term longer than his sentence, Spangler was retried and convicted of a lesser charge, involuntary manslaughter. He then sought compensation for the extra time he spent in prison.Spangler's initial conviction was upheld by the Court of Appeals. However, he later filed a motion arguing that he received constitutionally deficient assistance of counsel. The district court agreed, finding that Spangler's trial counsel failed to investigate his mental health status and its effect on his state of mind when he shot Martinez. This failure was deemed prejudicial to Spangler, and a new trial was ordered. The Court of Appeals affirmed this decision.In the retrial, Spangler was again convicted, but this time of involuntary manslaughter rather than second-degree murder. He was released based on time served, having served about four-and-a-half years beyond the sentence imposed for his involuntary manslaughter conviction. Spangler then filed a civil action seeking compensation for the time he spent in prison beyond his involuntary manslaughter sentence.The Supreme Court of the State of Kansas affirmed the district court's decision that Spangler's own conduct caused or brought about his conviction, thus precluding any recovery. The court interpreted the statute to reflect the Legislature's intent to impose a common-sense limitation: Only someone innocent of the criminal conduct supporting the underlying conviction may pursue a claim for damages. Therefore, a claimant like Spangler, who stands convicted of a lesser included offense based on the same charge as a previous conviction, is not eligible to seek relief. View "In re Wrongful Conviction of Spangler" on Justia Law

The Supreme Court of the State of Kansas has upheld the decision of the lower courts in a case involving a plaintiff, Jason Unruh, who alleged that the City of Wichita police officers used excessive force during his arrest. The plaintiff was apprehended after leading police on a car chase and was subsequently subdued while attempting to collect drugs that had spilled onto the ground. Nearly 23 months later, the plaintiff sued for personal injuries, alleging that the officers negligently used excessive force during his arrest. The case focused on whether the plaintiff's claim was for civil battery, which has a one-year statute of limitations, or negligence, which has a longer time limit. The court found that the plaintiff's claim was essentially a battery claim since the officers intentionally used force to make a lawful arrest. The court further clarified that negligence and battery are distinct legal concepts with different elements. The court noted that a negligence claim requires proof of a legally recognized duty that the defendant breached, causing the plaintiff's injuries. The plaintiff failed to establish that the officers owed him a special duty independent of the force used. As such, the plaintiff's claim was time-barred under the one-year statute of limitations for battery. The court affirmed the judgments of the lower courts. View "Unruh v. City of Wichita" on Justia Law

The Supreme Court affirmed the order of the district court reversing its order suppressing evidence found in the car that Defendant was driving on two separate occasions where law enforcement discovered drugs and other contraband, holding that the district court did not abuse its discretion in reversing its suppression order but erred in admitting prior drug use.Defendant was convicted by a jury of two counts of possessing methamphetamine and four counts of possessing drug paraphernalia with intent to use to distribute. The court of appeals reversed and remanded for a new trial on the ground that the district court erroneously allowed the State to introduce evidence relating to Defendant's prior convictions for similar crimes. The Supreme Court affirmed, holding (1) the district court erred in admitting prior drug crime evidence, and the error was not harmless; and (2) the district court did not abuse its discretion in granting the State's motion to reconsider its erroneous suppression ruling. View "State v. Campbell" on Justia Law

The Supreme Court affirmed Defendant's convictions for several crimes after he intentionally set a fire that damaged several apartments, holding, among other things, that the Kansas Legislature has defined the unit of prosecution for aggravated arson as each damaged building or property in which there is a person.Defendant intentionally set fire in the stairwell in front of his daughter's apartment, leading to his conviction, following a jury trial, of six counts of aggravated arson, three counts of attempted first-degree murder, and one count of animal cruelty. On appeal, Defendant argued, among other things, that the district court judge violated his right to be free from double jeopardy by sentencing him on six counts of aggravated arson when the arsonist started only one fire. The Supreme Court disagreed and affirmed, holding (1) Defendant's right to be free from double jeopardy was not violated; (2) the State presented sufficient evidence to support Defendant's convictions for attempted first-degree murder; and (3) the trial judge did not err in denying Defendant's untimely motion for a new trial. View "State v. Buchanan" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court's ruling in this eminent domain case between Tenants and City involving the requirement that a condemning authority provide certain relocation benefits and assistance to those displaced by the government's exercise of eminent domain, holding that the district court lacked subject matter jurisdiction over Tenants' petition to recover relocation expenses.Specifically, the Supreme Court held (1) the district court lacked subject matter jurisdiction over Tenants' petition because the Kansas Eminent Domain Procedure Act (EDPA), Kan. Stat. Ann. 26-501 et seq., neither provides a private right of action to recover relocation benefits nor authorizes judicial review of relocation-benefit determinations in eminent-domain appeals; (2) while the Kansas Relocation Assistance for Persons Displayed by Acquisition of Real Property Act (KRA), Kan. Stat. Ann. 58-3501 et seq., does provide an administrative remedy to vindicate the statutory right to relocation benefits, Tenants' failure to exhaust this administrative remedy deprived the district court of subject matter jurisdiction under the KRA; and (3) while Kan. Stat. Ann. 60-2101(d) authorizes appeals to the district court from certain final judgments and orders of a political subdivision, the statute did not apply in this case. View "Kan. Fire & Safety Equipment v. City of Topeka" on Justia Law

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

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

The Supreme Court affirmed the decision of the district court denying Defendants' motion to withdraw his guilty plea under Kan. Stat. Ann. 22-3210 and his subsequent motion under Kan. Stat. Ann. 60-1507 alleging ineffective assistance of counsel and involuntariness when he entered the plea, holding that the district court did not err.On appeal, the Supreme Court noted that Defendant did not preserve any issue on appeal as it related to his section 60-1507 motion and that Defendant made new arguments that were inappropriately raised for the first time on appeal. As to the denial of Defendant's motion to withdraw his plea under Kan. Stat. Ann. 22-3210(d)(2), the Supreme Court held that the district court did not abuse its discretion in denying Defendant's motion to withdraw plea. View "Shelton-Jenkins v. State" on Justia Law

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