Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and aggravated robbery and his resulting sentences, holding that there was no reversible error.Defendant was found guilty by a jury of committing first-degree premeditated murder and aggravated robbery when he was fifteen years old. Defendant was sentenced life imprisonment for the murder conviction and a consecutive sixty-one months' term of imprisonment for the robbery conviction. The Supreme Court affirmed, holding (1) the district court did not err by not giving an instruction on voluntary manslaughter-heat of passion; (2) Defendant failed to show that the prosecutor erred; and (3) Defendant's sentence did not violate the Eighth Amendment's prohibition of cruel and unusual punishment under the principles announced in Miller v. Alabama, 567 U.S. 460 (2012). View "State v. Gulley" on Justia Law

The Supreme Court reversed the panel of the court of appeals that applied the 2018 amendments to Kan. Stat. Ann. 8-1567, the driving under the influence (DUI) statute, to Defendant, who committed a DUI before, but was sentenced after, the amendments came into effect, holding that the court of appeals erred.The Supreme Court clarified the general rule established in State v. Reese, 333 P.3d 149 (Kan. 2014), that courts should apply the DUI sentencing provisions in effect at the time of sentencing but holding that a sentencing court should apply the version of section 8-1567 in effect at the time of sentencing unless the Legislature amended the statutory provisions after the offense was committed and that amendment increases the defendant's penalty. The Court remanded the matter to the district court for resentencing under the sentencing provisions in effect when Defendant committed the DUI, holding that applying the 2018 amendments to Defendant at sentencing would increase his punishment in violation of the Ex Post Facto Clause. View "State v. Patton" on Justia Law

The Supreme Court affirmed Defendant's death sentence imposed in connection with his conviction for capital murder, holding that Defendant was not entitled to relief on the penalty phase issues before the Court on remand from the United States Supreme Court in Kansas v. Carr, 477 U.S. 108 (2016).In its previous decision, the Supreme Court affirmed Defendant's conviction but vacated his death sentence, concluding that the trial court violated Defendant's Eighth Amendment right to an individualized sentencing determination by refusing to sever the trial's penalty phase from that of his codefendant brother. On remand, the Supreme Court affirmed Defendant's death sentence, holding (1) the record supported the findings that one or more aggravating circumstances existed and that any mitigating circumstances were insufficient to outweigh the aggravating circumstances; and (2) Defendant received a fair trial. View "State v. Carr" on Justia Law

The Supreme Court affirmed Defendant's sentence of death imposed in connection with his conviction for capital murder, holding that the sentence was not "imposed under the influence of passion, prejudice or any other arbitrary factor." See Kan. Stat. Ann. 21-6619(c)(1).Defendant was convicted of capital murder and sentenced to death. The Supreme Court affirmed the convictions but vacated the death sentencing, holding that the failure to sever the penalty phase violated Defendant's right to an individualized sentencing determination under the Eighth Amendment. However, in Kansas v. Carr, 477 U.S. 108 (2016), the United States Supreme Court held that the trial court's failure to Defendant's penalty phase did not implicate either the Eighth Amendment or the Due Process Clause. On remand, the Supreme Court addressed penalty phase issues that remained unresolved. The Court then affirmed Defendant's sentence, holding that Defendant received a fair trial and that any mitigating circumstances were insufficient to outweigh the aggravating circumstances. View "State v. Carr" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, holding that the errors committed during Defendant's trial did not affect the jury's verdict.Specifically, the Supreme Court held (1) there was no error in the admission of an autopsy photograph; (2) the prosecutor erred in closing argument by repeatedly use the phrase "we know" before discussing controverted facts, but the error was harmless; (3) presuming that the district court erred in not instructing the jury on the limited purpose for which the judge admitted some evidence, the error did not affect the verdict; (4) there was no error when the district court listed the jury's choice of finding Defendant guilty before listing the option of not guilty on the verdict form; and (5) the cumulative errors in this case did not affect the outcome. View "State v. Alfaro-Valleda" on Justia Law

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 reversed the decision of the court of appeals affirming the judgment of a federal district court granting summary judgment in favor of Defendants on Plaintiff's federal claims and declining to exercise supplemental jurisdiction over her state law claims, holding that the doctrine of res judicata did not prevent Plaintiff from bringing the state law claims in state court.Plaintiff sued the City of Wichita and one of its police officers in the United States District Court for the District of Kansas, alleging federal civil rights violations and state law tort claims. The federal district court granted summary judgment in favor of Defendants on the federal claims and declined to exercise supplemental jurisdiction over Plaintiff's state law claims. Plaintiff refiled her state law claims in Sedgwick County District Court, which held that Plaintiff's state law claims were barred by res judicata. The Supreme Court reversed, holding that when a federal court declines to exercise supplemental jurisdiction over state law claims and dismisses those claims without prejudice, there has been no final judgment on those state law claims, and res judicata does not preclude a litigant from bringing those claims in state court. View "Herington v. City of Wichita" 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