beyond-a-reasonable-doubt standard (Kansas) · Go Syfert
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beyond-a-reasonable-doubt standard in Kansas

17 Kansas opinions name it 2 courts 1993–2026 4 in the last five years

The cases below were cited by Kansas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Patterson v. Cowley County, Kansasgreen
kan · 2018 · cited in 2 Kansas opinions naming this issue, 2020–2021
2 sentences

2021See Patterson v. Cowley County, Kansas, 307 Kan. 616, 626 , 413 P.3d 432 (2018) ('We generally presume "the legislature does not intend to enact useless or meaningless legislation."').

2021See Patterson v. Cowley County, Kansas, 307 Kan. 616, 626 , 413 P.3d 432 (2018) ('We generally presume "the legislature does not intend to enact useless or meaningless legislation."').

22
State v. Sotogreen
kan · 2014 · cited in 2 Kansas opinions naming this issue, 2014–2014
2 sentences

2014See Soto, 299 Kan. at 129 .

2014Soto, 299 Kan. at 129 .

12
McKeiver v. Pennsylvaniagreen
scotus · 1971 · cited in 2 Kansas opinions naming this issue, 2008–2008
2 sentences

2008Noting that the “Sixth Amendment . . . speaks of denial of rights to ‘any person,’ not denial of rights to ‘any adult person,’ ” the dissenting justices discerned no difference between allowing juveniles the right to a jury trial and the previously granted rights to notice, counsel, protection against self-incrimination, confrontation, and conviction under the beyond a reasonable doubt standard. 403 U.S. at 560-61 (Douglas, J., dissenting).

2008Noting that the "Sixth Amendment . . . speaks of denial of rights to `any person,' not denial of rights to `any adult person,'" the dissenting justices discerned no difference between allowing juveniles the right to a jury trial and the previously granted rights to notice, counsel, protection against self-incrimination, confrontation, and conviction under the beyond a reasonable doubt standard. 403 U.S. at 560-61 , 91 S.Ct. 1976 (Douglas, J., dissenting).

12
State v. Hiltgreen
kan · 2014 · cited in 1 Kansas opinions naming this issue, 2017–2017
2 sentences

2017Because the judge, rather than the jury, found the four aggravating factors existed, and did so on a preponderance-of-the- evidence rather than a beyond-a-reasonable-doubt standard, Hilt's Sixth Amendment right to a jury trial, as interpreted in Alleyne, was violated." 299 Kan. at 203 .

2017Furthermore, we concluded that Hilt was not one of the rare cases where a hard 50 Alleyne error can be declared harmless. 299 Kan. at 204-05 ("[W]e cannot say on the 7 record before us that (1) proof of the aggravators was so overwhelming that their existence was certainly established, and (2) no rational factfinder would decide beyond a reasonable doubt that the mitigators advanced by Hilt outweighed the State's aggravators.").

11
In the Interest of B.D.-Y.green
kan · 2008 · cited in 1 Kansas opinions naming this issue, 2010–2010
1 sentence

2010See 286 Kan. 686 , Syl. ¶ 2.

11
O'Dell v. Netherlandgreen
scotus · 1997 · cited in 1 Kansas opinions naming this issue, 2001–2001
2 sentences

2001Ed.2d 799 (1963), to illustrate type of rule within watershed exception); Levan, at 278 (‘Shifting an element of the offense from jury to judge and utilizing a preponderance rather than a beyond a reasonable doubt standard does not implicate fundamental fairness or relate to the accuracy of the conviction or sentence.’); see *877 also O’Dell v. Netherlands 521 U.S. 151, 167 , 117 S. Ct. 1969 , 138 L.

2001Ed.2d 799 (1963), to illustrate type of rule within watershed exception); Levan, at 278 (‘Shifting an element of the offense from jury to judge and utilizing a preponderance rather than a beyond a reasonable doubt standard does not implicate fundamental fairness or relate to the accuracy of the conviction or sentence.’); see *877 also O’Dell v. Netherlands 521 U.S. 151, 167 , 117 S. Ct. 1969 , 138 L.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Kansas. Read the followed side critically anyway.

Also cited on this issue (11)

CaseCitedYears
State v. Wilson green
kan · 2006
2 sentences

2026The Kansas Supreme Court has long held that the beyond a reasonable doubt standard need not be defined, because "[n]o definition or explanation can make any clearer what is meant by the phrase 'reasonable doubt' than that which is imparted by the words themselves." State v. Wilson, 281 Kan. 277 , Syl. ¶ 4, 130 P.3d 48 (2006).

2026The Kansas Supreme Court has long held that the beyond a reasonable doubt standard need not be defined, because "[n]o definition or explanation can make any clearer what is meant by the phrase 'reasonable doubt' than that which is imparted by the words themselves." State v. Wilson, 281 Kan. 277 , Syl. ¶ 4, 130 P.3d 48 (2006).

12026–2026
In re Adoption of C.L. green
kan · 2018
1 sentence

2024In re Adoption of C.L., 308 Kan. 1268 , 1278, 427 P.3d 951 (2018).

12024–2024
State v. Johnson green
kan · 2019
1 sentence

2022The State's argument on this point is confusing, but it seems to assert the district court applied a beyond a reasonable doubt standard presumably because the district court cited a case—State v. Johnson, 310 Kan. 835 , 450 P.3d 790 (2019)—that dealt with the sufficiency of evidence at a jury trial to establish which version of the criminal threat offense the defendant committed.

12022–2022
State v. King green
kan · 2009
2 sentences

2010King, 288 Kan. at 351 , 204 P.3d 585 ; Ruff, 252 Kan. at 634 , 847 P.2d 1258 .

2010King, 288 Kan. at 351 , 204 P.3d 585 ; Ruff, 252 Kan. at 634 , 847 P.2d 1258 .

12010–2010
State v. Ruff green
kan · 1993
2 sentences

2010King, 288 Kan. at 351 , 204 P.3d 585 ; Ruff, 252 Kan. at 634 , 847 P.2d 1258 .

2010King, 288 Kan. at 351 , 204 P.3d 585 ; Ruff, 252 Kan. at 634 , 847 P.2d 1258 .

12010–2010
State v. Cody green
kan · 2001
2 sentences

2008On this issue, we finally point to the decision of State v. Cody, 272 Kan. 564 , 35 P.3d 800 (2001), where Cody pled guilty to criminal charges, and the court imposed an upward departure sentence based on Cody’s admissions, rather than based on facts found beyond a reasonable doubt by a unanimous jury.

2008On this issue, we finally point to the decision of State v. Cody, 272 Kan. 564 , 35 P.3d 800 (2001), where Cody pled guilty to criminal charges, and the court imposed an upward departure sentence based on Cody’s admissions, rather than based on facts found beyond a reasonable doubt by a unanimous jury.

12008–2008
Lambrix v. Singletary green
scotus · 1997
2 sentences

2001Ed.2d 351 (1997) (defendant’s right to advise capital sentencing jury about parole eligibility not watershed rule); Lambrix v. Singletary, 520 U.S. 518, 539-40 , 117 S. Ct. 1517 , 137 L.

2001Ed.2d 351 (1997) (defendant’s right to advise capital sentencing jury about parole eligibility not watershed rule); Lambrix v. Singletary, 520 U.S. 518, 539-40 , 117 S. Ct. 1517 , 137 L.

12001–2001
State v. Spain green
kan · 1998
2 sentences

2001“When the legislature eliminated the jury from the determination, it removed the express standard of proof.” State v. Spain, 263 Kan. 708, 711 , 953 P.2d 1004 (1998).

2001“When the legislature eliminated the jury from the determination, it removed the express standard of proof.” State v. Spain, 263 Kan. 708, 711 , 953 P.2d 1004 (1998).

12001–2001
Victor v. Nebraska green
scotus · 1994
2 sentences

1996Ed. 2d 583, 590 , 114 S. Ct. 1239 (1994), the United States Supreme Court stated: “The beyond a reasonable doubt standard is a requirement of due process, but the Constitution neither prohibits trial courts from defining reasonable doubt nor requires them to do so as a matter of course.” Victor held that a definition of reasonable doubt almost identical to the definition in this case did not violate due process.

1996The Court reasoned that other words and phrases in the definition itself helped to define the troublesome phrases of “moral evidence” and “moral certainty,” 511 U.S. at 10-17 .

11996–1996
State v. Walker green
kan · 1993
1 sentence

1993Willis discusses Lockett v. Ohio, 438 U.S. 586 , and highlights the fact that the Court determined that “[a]ny statute that prevents the sentencer from giving independent mitigating weight to such considerations is ‘unacceptable and incompatible with the commands of the Eighth and Fourteenth Amendments.’ 438 U.S. at 605 .” Willis believes that the jury was effectively precluded from considering mitigating factors by the use of the beyond a reasonable doubt standard. *132 We rejected a similar contention in State v. Walker, 252 Kan. at 307 , and do so here.

11993–1993
Lockett v. Ohio green
scotus · 1978
2 sentences

1993Willis discusses Lockett v. Ohio, 438 U.S. 586 , and highlights the fact that the Court determined that “[a]ny statute that prevents the sentencer from giving independent mitigating weight to such considerations is ‘unacceptable and incompatible with the commands of the Eighth and Fourteenth Amendments.’ 438 U.S. at 605 .” Willis believes that the jury was effectively precluded from considering mitigating factors by the use of the beyond a reasonable doubt standard. *132 We rejected a similar contention in State v. Walker, 252 Kan. at 307 , and do so here.

1993Willis discusses Lockett v. Ohio, 438 U.S. 586 , and highlights the fact that the Court determined that “[a]ny statute that prevents the sentencer from giving independent mitigating weight to such considerations is ‘unacceptable and incompatible with the commands of the Eighth and Fourteenth Amendments.’ 438 U.S. at 605 .” Willis believes that the jury was effectively precluded from considering mitigating factors by the use of the beyond a reasonable doubt standard. *132 We rejected a similar contention in State v. Walker, 252 Kan. at 307 , and do so here.

11993–1993

Statutes the citing opinions construe

KS § K.S.A. § 21-4635 (4) KS § K.S.A. § 21-4716 (4) KS § K.S.A. § 22-4906 (4) KS § K.S.A. § 60-401 (4) KS § K.S.A. § 21-3401 (3) KS § K.S.A. § 21-4718 (3) KS § K.S.A. § 21-6804 (3) KS § K.S.A. § 22-3601 (3) KS § K.S.A. § 38-2269 (3) KS § K.S.A. § 60-404 (3) KS § K.S.A. § 60-455 (3) KS § K.S.A. § 60-460 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 563 (1980–2026) CA 435 (1956–2026) OH 72 (1992–2026) WA 70 (1974–2026) TN 51 (1994–2016) IL 50 (1979–2026) PA 46 (1976–2026) GA 40 (1982–2023) MS 26 (1983–2023) NV 26 (1980–2022) LA 23 (1976–2022) CO 23 (1990–2026) NM 21 (2001–2025) WI 20 (1990–2025) MD 19 (1978–2022) NC 19 (1977–2025) NJ 18 (1989–2025) KS 17 (1993–2026) MI 16 (1971–2022) FL 16 (1970–2026) MN 15 (1978–2024) AL 13 (1994–2012) UT 12 (1983–2025) NY 12 (1971–2026) CT 11 (1991–2020) OR 11 (1977–2025) MO 11 (1983–2021) AZ 10 (1984–2026) OK 9 (1995–2024) VT 9 (1992–2026) IA 8 (1981–2017) VA 7 (1996–2023) NH 7 (1981–2015) SD 7 (1981–2022) AK 7 (1980–2021) IN 6 (1988–2017) DC 6 (1979–2020) MA 5 (1978–2007) WY 5 (2012–2025) NE 5 (1996–2023) RI 5 (1970–2011) MT 4 (1996–2018) HI 4 (1981–2007) KY 4 (2001–2026) VI 3 (2011–2013) AR 2 (2004–2008) ME 2 (1983–2018)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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