Category: Trials

With Court’s Leave, Prosecutors May Dismiss Grand Jury Indictments

State v. Bird, No. 120,816 (Kan. Ct. App., Feb. 19, 2021). Author: Andrew Tague, Staff Editor Issue: Under Kansas common law, a prosecutor may dismiss or reduce any charge against a criminal defendant.  Kan. Stat. Ann. § 22-3015(b), …

Supplementing the Pattern Premeditation Jury Instruction: Necessary or Unnecessarily Confusing?

Author: Dahnika Short, Staff Editor State v. Stafford, No. 120,481 (Kan. Dec. 23, 2020) Issue: Was the addition of a Bernhardt instruction to the premeditation Pattern Instruction for Kansas (PIK) confusing and therefore legally inappropriate? Answer: No.  There …

The Language Conduit Rule: Admitting Interpreters’ Hearsay Statements in Kansas

Author: Cayce Good, Staff Editor State v. Gutierrez-Fuentes, No. 120,339, (Kan. Ct. App., Nov. 25, 2020) Issue:  Under Kan. Stat. Ann. § 60-460, statements made by a person other than a witness testifying in court are considered inadmissible …

Manifest Necessity Required to Declare Jury Deadlocked

Author: Emily Otte, Executive Comments Editor State v. Kornelson, No. 118,091 (Kan. July 2, 2020) Issue: Whether the goading standard or the manifest necessity standard applies to a double jeopardy claim when the defendant does not object or …

Kansas Law Review blog

Kansas District Courts’ Authority to Interpret Ambiguous Jury Verdicts

Author: Ellen Bertels, Comments Editor State v. Brown, No. 115,817 (Kan. June 5, 2020). Issue:  Can a district court invoke the surplusage rule and discard part(s) of a jury verdict form when the form incorrectly lists the crimes …

Understanding Jury Trial Waivers

State v. Harris, No. 117,362 (Kan., Apr. 17, 2020). Issue:  Is telling both your attorney, who has informed you of your rights, and the district court, which asks for a choice between a “bench trial and the case …

Probation Revocation Hearings Require Competency

State v. Gonzalez, No. 120,179 (Kan. Ct. App. Dec. 27, 2019). Issue: There is no statutory protection requiring a defendant be competent at a hearing to revoke his probation. Is competence constitutionally protected nonetheless at this stage? Answer: …

Voluntary Intoxication Not a Defense to Reckless Homicide

State v. Claerhout, No. 115,227 (Kan. Dec. 6, 2019). Issue:  (1) Did the trial court correctly admit a past diversion agreement to demonstrate a a knowledge of the dangers of driving while intoxicated? (2) Is voluntary intoxication a …

Updated Transitional Release Requirements

In re Care & Treatment of Quillen, No. 120, 184 (Kan. Ct. App. Oct. 18, 2019). Issue: Is the State required to prove “serious difficulty in controlling behavior,” when arguing a person does not meet the qualifications for …

Party Benefitting from Erroneous Judicial Comment Bears Burden

State v. Boothby, No. 116,505 (Kan. Sept. 6, 2019). Issue: A district judge made an erroneous comment regarding Boothby’s case in front of the jury.  Is an erroneous judicial comment made in front of a jury that is not part …