Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of first-degree premeditated murder, aggravated kidnapping, and aggravated robbery. After the sentencing judge found by a preponderance of the evidence the existence of four aggravating factors, Defendant received a hard fifty life sentence for the first-degree murder conviction. Defendant appealed, raising nine issues challenging his convictions and two challenging his sentences. The Supreme Court (1) affirmed Defendant’s convictions, thus rejecting Defendant’s claims of reversible error; and (2) vacated Defendant’s sentence for first-degree murder, holding that Defendant’s Sixth Amendment right to a jury trial, as interpreted in Alleyne v. United States, was violated because the judge, rather than the jury, found the four aggravating factors existed and did so on a preponderance-of-the-evidence standard, rather than a beyond-a-reasonable-doubt standard. View "State v. Hilt" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and aggravated robbery. Before trial, the State moved for a determination as to the admissibility of Defendant’s inculpatory statements to police. The district court conducted an evidentiary hearing at which Defendant had the opportunity to challenge the voluntariness of the statements. The district court allowed the statements to be admitted. After he was convicted and sentenced, Defendant appealed, arguing (1) the district court erred in denying his motion to suppress inculpatory statements he made to the police, and (2) structural error occurred when he was not allowed to testify in support of his motion to reconsider the trial court’s earlier ruling that his statements to police were voluntarily given. The Supreme Court affirmed, holding that the district court (1) did not err in determining that Defendant’s statements to the police were voluntary and knowingly given; and (2) did not abuse its discretion in denying Defendant a second opportunity to testify and his request proffer his testimony at the motion to reconsider. View "State v. Gibson" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to life imprisonment without the possibility of parole for fifty years. The Supreme Court affirmed Defendant’s conviction but vacated his sentence, holding that Kansas’ hard fifty sentencing scheme violates the Sixth Amendment to the federal Constitution as interpreted in Alleyne v. United States and Ring v. Arizona because it permits a judge to find by a preponderance of the evidence the existence of one or more aggravating factors necessary to impose an increased mandatory minimum sentence, rather than requiring a jury to find the existence of the aggravating circumstances beyond a reasonable doubt. Remanded for resentencing. View "State v. Soto" on Justia Law

After a jury trial, Defendant was convicted of aggravated indecent liberties with a child. The Supreme Court reversed in part, holding that the trial court denied Defendant his right under the Sixth Amendment to have the effective assistance of counsel at a critical stage of the criminal proceedings against him when the court denied Defendant’s pro se motions for a new trial without first appointing new conflict-free counsel to assist Defendant in arguing the motions. Remanded for appointment of new counsel and instructions to hold a new holding on Defendant’s pro se motions for new trial. View "State v. Sharkey" on Justia Law

The State charged Defendant with possession of methamphetamine after law enforcement officers stopped Defendant’s vehicle based on a turn signal violation, searched the vehicle because they detected a very strong odor of alcohol coming from within the vehicle, and discovered methamphetamine during the search. Defendant filed a motion to suppress the fruits of the warrantless search. The district court denied the motion, concluding that the strong odor of alcohol emanating from within the vehicle established probable cause for the officers to search the vehicle for an open container of alcohol. The Supreme Court reversed, holding that the search was unlawful because the officers failed to acquire additional inculpatory facts relating to the crime being investigated before commencing their search of the vehicle. View "State v. Stevenson" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated indecent liberties with a child and sentenced to hard twenty-five life sentences imposed under Jessica’s Law. The Supreme Court reversed Defendant’s convictions and remanded the case for a new trial, holding (1) the district court erred in failing to give a unanimity jury instruction; (2) the district court abused its discretion in handling Defendant’s motion for a mistrial based on a law enforcement officer’s violation of an order in limine when the officer volunteered that Defendant invoked his postarrest right to remain silent and described the circumstances of that invocation because Defendant’s constitutional rights were violated by the officer’s testimony; and (3) the cumulative impact of these errors substantially prejudiced Defendant’s right to a fair trial. View "State v. Santos-Vega" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to one count of rape of a child and one count of sexual exploitation of a child. The district court sentenced Defendant to life imprisonment with a mandatory minimum term of twenty-five years for his rape of a child conviction and imposed lifetime postrelease supervision for both convictions. Defendant appealed the lifetime postrelease supervision portion of his sexual exploitation sentence. The Supreme Court (1) affirmed the sexual exploitation sentence, holding that the sentence did not violate the Eighth Amendment; and (2) vacated sua sponte the lifetime postrelease supervision portion of Defendant’s rape sentence, holding that the district court erred in imposing lifetime postrelease supervision for Defendant’s rape conviction as part of sentencing him to an off-grid indeterminate life sentence. View "State v. Williams" on Justia Law

Pursuant to a plea agreement, Defendant pled no contest to two counts of felony murder and one count of aggravated arson. Thereafter, Defendant filed a motion to withdraw his no contest pleas to the three charges. The district judge denied the motion, concluding that Defendant failed to show that manifest injustice would result if he was unable to withdraw his pleas. The Supreme Court affirmed, holding (1) the judge did not abuse his discretion in failing to inquire explicitly at Defendant’s plea hearing about promises made to Defendant; (2) Defendant’s defense counsel did not provide ineffective assistance; and (3) the record did not support Defendant’s assertion that he did not understand the meaning and consequences of a no contest plea. View "State v. Morris" on Justia Law

After a jury trial, Appellant was convicted of aggravated indecent liberties with a child, rape, aggravated criminal sodomy, and sexual exploitation of a child. The Supreme Court affirmed Appellant’s convictions but vacated Appellant’s sentence, holding (1) the district court did not err in admitting into evidence Appellant’s prior conviction for indecent liberties with a child and two home videotapes; (2) the district court issued an erroneous limiting instruction, but the instruction was not clearly erroneous; (3) Appellant waived his allegation of error on Confrontation Clause grounds by failing to timely and specifically object on that basis; (4) the prosecutor improperly speculated on facts not in evidence during his rebuttal closing argument, but the error did not require reversal; and (5) the sentencing court improperly imposed a mandatory minimum sentence instead of departing to a guidelines sentence after granting Appellant’s motion to depart. Remanded. View "State v. Dean" on Justia Law

In 1995, Appellant pleaded guilty to first-degree felony murder and aggravated robbery for crimes Appellant committed when he was fourteen years old. Approximately twelve years later, Appellant filed a pro se motion to withdraw his guilty pleas. Appellant also argued that his aggravated robbery sentence was illegal because his juvenile adjudications were used both to certify him for adult prosecution and to compute his criminal history score. The district court denied Appellant’s motion without conducting an evidentiary hearing. The Supreme Court affirmed, holding (1) Appellant failed to demonstrate the manifest injustice required by Kan. Stat. Ann. 22-3210(d) to withdraw his guilty pleas; and (2) Appellant’s aggravated robbery sentence, which was within the presumptive sentence for that crime based on Appellant’s criminal history score, was not illegal. View "State v. Kelly" on Justia Law