Archive Search
The Need for Specificity: When Courts Must Require a Bill of Particulars
State v. Bee, 592 P.3d 355 (Kan. Ct. App. 2026) Author: Staff Editor Eleanor Boone Issue: Did the district court abuse its discretion in denying the defendant’s motion for a bill of particulars pursuant to Kan. Stat. Ann. § 22-3201(f)? Answer: Yes. The court abused its discretion by…
The Expiration of Probation Exasperation
Author: Staff Editor Cole Abendroth State v. Douglas, No. 128,766 (Kan. Ct. App. July 31, 2026) Issue: For a six-month probation extension entered on July 24, 2023, does the probation extension expire on January 23, 2024? Answer: No, the probation extension would instead expire on January 24,…
Should I Stay or Should I Go?: Miranda Rights After Officers Leave the Interrogation Room
State v. Gardner, No. 129,439, 2026 WL 2794371, (Kan. Ct. App. Sept. 18, 2026)Author: Staff Editor Aidan BhargavaIssue: Are statements a defendant makes while alone in an interrogation room admissible when the statements occur between interrogation sessions conducted after the…
When the Victim Speaks: Admitting Statements Made by a Murder Victim
State v. Bey, No. 127,537, (Kan. Mar. 13, 2026). Staff Editor Sophia Zheng April 6, 2026 Issue: Did the district court err in admitting Sprague’s out-of-court statement that “if she ever died, [Bey] would be the one to kill her” under the necessity exception outlined in Kan. Stat. Ann. § 60-…
Not Every Robbery Is a Person Felony: Focusing on Statutory Elements
State v. Evans, 127,467, (Kan. Mar. 6, 2026). Staff Editor Bella Price March 21, 2026 Issue: Whether the State should divide and consider the separate elements of an out-of-state statute when classifying an out-of-state crime as a person or nonperson felony. Answer: Yes. The circumstances…
It Is Not Prosecutorial Error to Refute Defense’s Arguments
State v. Arroyo, No. 128,013, (Kan. Feb. 13, 2026). Staff Editor Mary Duncan March 14, 2026 Issue: Does a Prosecutor always error by suggesting that the defendant has just as much opportunity to put evidence before a jury as the Prosecution does? Answer: No. There is no prosecutorial…
Apples and . . . More Apples: When Crimes are Comparable for Sentencing
State v. McCray, No. 125,798, (Kan. Dec. 12, 2025). Staff Editor Keith Marshall February 23, 2026 Issue: When Kansas courts decide whether an out-of-state conviction counts as a “person” crime for sentencing, do they consider the manner of liability? Answer: Not for crimes committed before Kansas…
Passcodes and the Fifth Amendment: When Must Police Re-Mirandize? Kansas Weighs In
State v. Harris, No. 125,936, (Kan. 2025). Staff Editor Trey Bohlender February 22, 2026 Issue: Whether detectives violated Harris’s Fifth Amendment privilege against self-incrimination by compelling him to involuntarily disclose his cell phone passcodes. Answer: No. Because the…
Conclusory Suppression Motion Preserves Nothing for Appeal
State v. Anderson, No. 126,770, (Kan. Jan. 13, 2026). Staff Editor Louis Christifano Jr. February 3, 2026 Issue: Did a defendant preserve a Fourth Amendment issue for appeal when his motion to suppress at trial alleged merely conclusory statements and stipulated facts, without explaining how…
Following Instructions: Factual Applicability of Child Endangerment and Self-Defense Jury Instructions
State v. Butler, No. 127,378, (Kan. Jan. 9, 2026). Staff Editor Landon Sloan January 24, 2026 Issue: Was refusing to instruct the jury on misdemeanor endangering a child harmless error and was an instruction on self-defense factually applicable when the defendant fired a gun towards fleeing…