Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of capital murder, aggravated burglary, and attempted rape. The district court imposed the death sentence for the capital murder conviction and time in prison for the remaining convictions. The Supreme Court remanded after finding reversible error relating to Defendant’s capital sentence. After a new sentencing proceeding, the district court imposed the death sentence for the capital murder conviction and prison sentences for the remaining convictions. Defendant appealed, raising several allegations of error. The Supreme Court affirmed Defendant’s capital murder conviction and his death sentence but reversed Defendant’s attempted rape conviction as multiplicitous, vacated his sentence for attempted rape, and remanded for resentencing on the other conviction of aggravated burglary, holding that an intervening change in the law required reversal of Defendant’s attempted rape conviction. View "State v. Kleypas" on Justia Law

After a jury trial, Defendant was convicted of premeditated first-degree murder. Defendant appealed, raising several claims of error, including claims of prosecutorial misconduct. The Supreme Court affirmed, holding (1) the State demonstrated beyond a reasonable doubt that a single error on the part of the prosecutor did not affect the outcome of the trial, and Defendant’s remaining prosecutorial misconduct claims were without merit; (2) Defendant did not meet the clear error standard for reversal based on the district judge’s early mistake in making statements to potential jurors before voir dire; (3) the district judge erred in omitting an instruction on reckless second-degree murder, but the jury would not have reached a different verdict had the instruction been given; and (4) cumulative error did not necessitate reversal. View "State v. Carter" on Justia Law

Defendant was charged with felony driving under the influence as a three-time offender, refusing a preliminary breath test, and transporting an open container. Defendant filed a motion to suppress evidence obtained when police officers entered his home without a search warrant. The district court judge denied the motion. The Court of Appeals affirmed. The Supreme Court affirmed, although its reasoning differed from that of the district judge and the Court of Appeals, holding (1) the officers had probable cause to arrest Defendant for driving under the influence before they entered his home; and (2) even if there was error, the error was not reversible. View "State v. Keenan" on Justia Law

Defendant was convicted of first-degree murder and aggravated burglary. The trial court sentenced Defendant to a hard twenty-five life sentence for the first-degree murder conviction. The Supreme Court affirmed, holding (1) the district court did not err in failing to instruct the jury on voluntary manslaughter, unintentional second-degree murder, and reckless involuntary manslaughter; (2) the district court did not err by excluding evidence that the shooting happened in a high crime area; (3) the district court did not err in denying Defendant’s request for a trial continuance; (4) the district court did not err in denying Defendant’s motion for new trial based on ineffective assistance of counsel; and (5) cumulative error did not deprive Defendant of a fair trial. View "State v. Johnson" on Justia Law

Defendant was charged with first-degree murder and criminal possession of a firearm. After a trial, the jury convicted Defendant of the firearm charge but failed to reach a verdict on the murder charge. The district court subsequently declared a mistrial. Before the State pursued a second trial on the murder charge, Defendant filed a motion to dismiss, arguing that any retrial would violate his rights under the Double Jeopardy Clause. The district court denied the motion. The Supreme Court dismissed Defendant’s appeal, holding that Kansas statutes only allow an appeal in the case of a final judgment, which requires a conviction and sentence, and therefore, Defendant’s appeal was not properly before the court and must be dismissed for want of jurisdiction. View "State v. Webb" on Justia Law

At issue in this case was Kansas’ speedy trial statute, which provides that a criminal case in which a defendant has been “held to answer on an appearance bond” shall be dismissed if a trial does not occur within 180 days after arraignment. In City of Elkhart v. Bollacker, the Supreme Court held that the legislature intended the statute to apply even when a defendant had not been held on an appearance bond. In the instant case, Defendant, who was not on bond, relied on the speedy trial statute in seeking dismissal of the criminal charges. The district court dismissed the charges because a trial did not take place within 180 days after Defendant’s arraignment. The Court of Appeals affirmed based on Bollacker. The Supreme Court overruled Bollacker, holding (1) the Bollacker court violated the rules of statutory interpretation, and (2) a defendant not held to answer on an appearance bond has no statutory speedy trial right under the statute. The Court, however, affirmed the dismissal of the charges against Defendant because its right to dismissal for a statutory speedy trial violation had vested under the prior binding law. View "State v. Spencer Gifts, LLC" on Justia Law

After a jury trial, Defendant was found guilty of felony murder, criminal discharge of a firearm at an occupied vehicle, and burglary. The district court sentenced Defendant to life without the possibility of parole for twenty years. The Supreme Court affirmed the convictions but vacated the lifetime postrelease supervision term, holding (1) the State presented sufficient evidence to support Defendant’s convictions for felony murder and criminal discharge of a firearm; (2) sufficient evidence supported Defendant’s vehicular burglary conviction; (3) the district court did not err in denying Defendant’s motion to suppress; (4) the district court’s jury instruction on aiding and abetting was not in error; (5) the district court did not violate Defendant’s Sixth Amendment rights by authorizing the state to prosecute Defendant as an adult; and (6) the district court erred by noting within the journal entry of judgment that Defendant was subjected to lifetime postrelease supervision for all of his convictions. Remanded. View "State v. Potts" on Justia Law

Petitioner entered a plea of no contest to charges of second-degree intentional murder, aggravated robbery, and conspiracy to commit aggravated robbery. Petitioner’s conviction and sentence were affirmed on appeal. Later, Petitioner was placed in administrative segregation in response to threats of gang violence and possible involvement in contraband trafficking. Petitioner filed a petition for writ of habeas corpus, alleging that his continued administrative custody, lasting over 1,000 days, violated his due process rights. The district court dismissed the petition. The court of appeals affirmed, ruling that, without at least a prima facie showing of unusually harsh conditions, continued incarceration in segregated custody does not infringe on a protected liberty interest. The Supreme Court granted in part Petitioner’s petition for review. Noting that Petitioner was no longer placed in administrative segregation, the Court denied relief, as Petitioner’s request for relief was moot, but the Court nevertheless issued this opinion to provide guidance to courts as they countered liberty interest claims in the future. The Court then concluded that duration of segregated placement is a factor that courts must consider in determining whether an inmate has met the standards for demonstrating a liberty interest infraction. View "Jamerson v. Heimgartner" on Justia Law

Petitioner, an inmate, was disciplined for violating K.A.R. 44-12-301, the regulatory prohibition on fighting. Petitioner filed a Kan. Stat. Ann. 60-1501 petition against the warden of the correctional facility where Petitioner was incarcerated, arguing that his due process rights were violated because the finding by the hearing officer that Petitioner violated K.A.R. 44-12-301 was unsupported by the evidence. The district court reversed the disciplinary hearing panel’s findings, ruling that the hearing officer could not have reasonably found Petitioner guilty. The court of appeals reversed. The Supreme Court reversed the judgment of the court of appeals and affirmed the district court’s ruling, holding that Petitioner was not accorded due process when he was found to have violated K.A.R. 44-12-301, as there was a complete failure of proof of one of the elements of the offense. View "May v. Cline" on Justia Law

After a bench trial, Defendant was found guilty of possession with marijuana with the intent to distribute. Defendant appealed the denial of his motion to suppress evidence resulting from a search of a house where he was staying. The search was conducted pursuant to an anticipatory search warrant which purported to give law enforcement authority to search the house once a suspicious package was successfully delivered to a resident of the house. The court of appeals affirmed, concluding that the district court did not err in finding that the search warrant was supported by probable cause and that Defendant’s retrieval of the package from the front porch while under police surveillance was sufficient to trigger execution of the search warrant. The Supreme Court affirmed, holding (1) there was a substantial basis for the district court judge’s determination that probable cause supported a search warrant of the home; (2) the event triggering execution of the search warrant - a controlled delivery of the package to a resident of the home - occurred in this case; and (3) the police acted appropriately when they entered the house pursuant to the search warrant. View "State v. Mullen" on Justia Law