gross deviation standard (Kansas) · Go Syfert
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gross deviation standard in Kansas

13 Kansas opinions name it 2 courts 2008–2026 5 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
State v. Gonzalezgreen
kan · 2018 · cited in 2 Kansas opinions naming this issue, 2019–2019
2 sentences

2019See State v. James, 309 Kan. 1280 , 1299, 443 P.3d 1063 (2019) (quoting K.S.A. 2018 Supp. 21-5202[j]) (differentiating between degrees of recklessness needed for two crimes; person acts "recklessly," is "reckless" when person consciously disregards substantial, unjustifiable risk "that circumstances exist or that a result will follow, and such disregard constitutes a gross deviation from the standard of care which a reasonable person would exercise in the situation"); see also State v. Gonzalez, 307 Kan. 575, 581 , 412 P.3d 968 (2018) (outlining requirements of unintentional second-degree murd

2019See State v. James, 309 Kan. 1280 , 1299, 443 P.3d 1063 (2019) (quoting K.S.A. 2018 Supp. 21-5202[j]) (differentiating between degrees of recklessness needed for two crimes; person acts "recklessly," is "reckless" when person consciously disregards substantial, unjustifiable risk "that circumstances exist or that a result will follow, and such disregard constitutes a gross deviation from the standard of care which a reasonable person would exercise in the situation"); see also State v. Gonzalez, 307 Kan. 575, 581 , 412 P.3d 968 (2018) (outlining requirements of unintentional second-degree murd

22
People v. Jonesgreen
colo · 1977 · cited in 2 Kansas opinions naming this issue, 2017–2017
2 sentences

2017With respect to the specific difference between recklessness and criminal negligence, Hall explained: "Criminal negligence requires that, 'through a gross deviation from the standard of care that a reasonable person would exercise,' the actor fails to perceive a substantial and unjustifiable risk that a result will occur or a circumstance exists. § 18-1-501(3); see also People v. Jones, 193 Colo. 250, 253-54 , 565 P.2d 1333, 1335 (1977) (discussing criminally negligent homicide).

2017With respect to the specific difference between recklessness and criminal negligence, Hall explained: "Criminal negligence requires that, 'through a gross deviation from the standard of care that a reasonable person would exercise,' the actor fails to perceive a substantial and unjustifiable risk that a result will occur or a circumstance exists. § 18-1-501(3); see also People v. Jones, 193 Colo. 250, 253-54 , 565 P.2d 1333, 1335 (1977) (discussing criminally negligent homicide).

22
State v. Dealgreen
kan · 2012 · cited in 3 Kansas opinions naming this issue, 2017–2019
2 sentences

2019We have previously addressed the differences between the intentional and reckless forms of second-degree murder in State v. Deal , 293 Kan. 872 , 884, 269 P.3d 1282 (2012).

2019Recklessness is not limited to "blind conduct." See James, 309 Kan. at 1299 (quoting State v. Deal, 293 Kan. 872, 884 , 169 P.3d 1282 [2012]) (even intentional blow can result in unintentional but reckless killing; "'[I]t is not the intent to inflict a blow but the intent to kill that is the focal point' of the distinction between intentional second-degree murder and unintentional but reckless second-degree murder."); see also Gentry, 310 Kan. at 727 (evidence reasonably supported theory shooter fired toward truck without intent to kill whoever might be inside).

13
State v. Plummergreen
kan · 2012 · cited in 1 Kansas opinions naming this issue, 2021–2021
1 sentence

2021See State v. Gentry, 310 Kan. 715 , 721, 449 P.3d 429 (2019) (holding involuntary manslaughter is a lesser included offense of first-degree premeditated murder); Plummer, 295 Kan. at 161 (holding lesser included offense instruction is legally appropriate).

11
State v. Gentrygreen
kan · 2019 · cited in 1 Kansas opinions naming this issue, 2021–2021
1 sentence

2021See State v. Gentry, 310 Kan. 715 , 721, 449 P.3d 429 (2019) (holding involuntary manslaughter is a lesser included offense of first-degree premeditated murder); Plummer, 295 Kan. at 161 (holding lesser included offense instruction is legally appropriate).

11
State v. Jamesgreen
kan · 2019 · cited in 1 Kansas opinions naming this issue, 2019–2019
1 sentence

2019See State v. James, 309 Kan. 1280 , 1299, 443 P.3d 1063 (2019) (quoting K.S.A. 2018 Supp. 21-5202[j]) (differentiating between degrees of recklessness needed for two crimes; person acts "recklessly," is "reckless" when person consciously disregards substantial, unjustifiable risk "that circumstances exist or that a result will follow, and such disregard constitutes a gross deviation from the standard of care which a reasonable person would exercise in the situation"); see also State v. Gonzalez, 307 Kan. 575, 581 , 412 P.3d 968 (2018) (outlining requirements of unintentional second-degree murd

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 (8)

CaseCitedYears
State v. Robinson green
kan · 2015
2 sentences

2024Regardless, in State v. Robinson, 303 Kan. 11, 284 , 363 P.3d 875 (2015), upon which Collins relies, the Kansas Supreme Court found an instruction erroneous when it found the instruction's language "was incomplete, inaccurate, and confusing." And similarly in State v. Horton, 300 Kan. 477, 491 , 331 P.3d 752 (2014), our Supreme Court stated a reviewing court "considers the instruction as a whole . . . to see whether it properly and fairly stated the law as applied to the facts of the case and could not have reasonably misled the jury." (Emphasis added.) Collins argues the second element of eac

2024Regardless, in State v. Robinson, 303 Kan. 11, 284 , 363 P.3d 875 (2015), upon which Collins relies, the Kansas Supreme Court found an instruction erroneous when it found the instruction's language "was incomplete, inaccurate, and confusing." And similarly in State v. Horton, 300 Kan. 477, 491 , 331 P.3d 752 (2014), our Supreme Court stated a reviewing court "considers the instruction as a whole . . . to see whether it properly and fairly stated the law as applied to the facts of the case and could not have reasonably misled the jury." (Emphasis added.) Collins argues the second element of eac

22024–2024
State v. Horton green
kan · 2014
2 sentences

2024Regardless, in State v. Robinson, 303 Kan. 11, 284 , 363 P.3d 875 (2015), upon which Collins relies, the Kansas Supreme Court found an instruction erroneous when it found the instruction's language "was incomplete, inaccurate, and confusing." And similarly in State v. Horton, 300 Kan. 477, 491 , 331 P.3d 752 (2014), our Supreme Court stated a reviewing court "considers the instruction as a whole . . . to see whether it properly and fairly stated the law as applied to the facts of the case and could not have reasonably misled the jury." (Emphasis added.) Collins argues the second element of eac

2024Regardless, in State v. Robinson, 303 Kan. 11, 284 , 363 P.3d 875 (2015), upon which Collins relies, the Kansas Supreme Court found an instruction erroneous when it found the instruction's language "was incomplete, inaccurate, and confusing." And similarly in State v. Horton, 300 Kan. 477, 491 , 331 P.3d 752 (2014), our Supreme Court stated a reviewing court "considers the instruction as a whole . . . to see whether it properly and fairly stated the law as applied to the facts of the case and could not have reasonably misled the jury." (Emphasis added.) Collins argues the second element of eac

22024–2024
State v. Krovvidi green
kan · 2002
2 sentences

2026Peery relies on State v. Krovvidi, 274 Kan. 1059 , 58 P.3d 687 (2002), to argue that something more, like intoxication or cell phone distraction, is needed to support a vehicular homicide conviction, so something more is also needed to support her reckless involuntary manslaughter conviction.

2026Peery relies on State v. Krovvidi, 274 Kan. 1059 , 58 P.3d 687 (2002), to argue that something more, like intoxication or cell phone distraction, is needed to support a vehicular homicide conviction, so something more is also needed to support her reckless involuntary manslaughter conviction.

12026–2026
State v. Mendez green
kan · 2024
1 sentence

2026Standard of Review "When a defendant challenges the sufficiency of the evidence, we review the evidence in a light most favorable to the State to determine whether a rational fact-finder 22 could have found the defendant guilty beyond a reasonable doubt." State v. Mendez, 319 Kan. 718 , 723, 559 P.3d 792 (2024).

12026–2026
State v. Hillard green
kan · 2022
1 sentence

2025"Generally, jury instructions patterned after statutes are legally proper." State v. Hillard, 315 Kan. 732 , 776, 511 P.3d 883 (2022).

12025–2025
State v. Gatlin green
kan · 2011
2 sentences

2020The Kansas Supreme Court has held: "To act recklessly, a defendant must know that he or she is putting others in imminent danger." State v. Gatlin, 292 Kan. 372, 377 , 253 P.3d 357 (2011).

2020The Kansas Supreme Court has held: "To act recklessly, a defendant must know that he or she is putting others in imminent danger." State v. Gatlin, 292 Kan. 372, 377 , 253 P.3d 357 (2011).

12020–2020
State v. Martinez green
kan · 2009
2 sentences

2016Clearly, a lesser included offense instruction on reckless second-degree murder would have been legally appropriate because "[r]eckless second-degree murder is a lesser included offense of premeditated first-degree murder." State v. Martinez, 288 Kan. 443, 453 , 204 P.3d 601 (2009).

2016Clearly, a lesser included offense instruction on reckless second-degree murder would have been legally appropriate because "[r]eckless second-degree murder is a lesser included offense of premeditated first-degree murder." State v. Martinez, 288 Kan. 443, 453 , 204 P.3d 601 (2009).

12016–2016
State v. Anderson green
moctapp · 2002
1 sentence

2008This charge required the State to prove “ ‘criminal negligence’ ” which is defined in part as a failure “ ‘to be aware of a substantial and unjus *528 tifiable risk that circumstances exist or a result will follow’ ” and the “ ‘failure constitutes a gross deviation from the standard of care which a reasonable person would exercise in the situation.’ ” 108 S.W.3d at 683 (quoting Mo. Rev.

12008–2008

Statutes the citing opinions construe

KS § K.S.A. § 21-5202 (9) KS § K.S.A. § 21-5403 (6) KS § K.S.A. § 21-5413 (6) KS § K.S.A. § 21-5405 (4) KS § K.S.A. § 21-6811 (4) KS § K.S.A. § 22-3504 (4) KS § K.S.A. § 21-5402 (3) KS § K.S.A. § 21-5404 (3) KS § K.S.A. § 21-6801 (3) KS § K.S.A. § 21-6804 (3) KS § K.S.A. § 60-261 (3) KS § K.S.A. § 60-455 (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 190 (1976–2026) NY 140 (1972–2025) IL 134 (1964–2026) CA 108 (1983–2026) PA 107 (1977–2026) TN 66 (1994–2026) OR 66 (1975–2026) MO 52 (1987–2025) GA 43 (1988–2026) CT 39 (1981–2025) KY 25 (1987–2026) UT 25 (1983–2026) ME 22 (1979–2025) AL 20 (1985–2025) NJ 19 (1979–2025) DE 16 (2003–2025) CO 15 (1982–2026) AZ 14 (1988–2024) WA 13 (1979–2024) KS 13 (2008–2026) NM 13 (2009–2023) HI 12 (1995–2026) AR 10 (1985–2026) VT 10 (1992–2025) MD 8 (1991–2022) AK 8 (1982–2023) MN 6 (1991–2015) WY 5 (1993–2024) NH 5 (2005–2017) LA 4 (1971–1991) FL 4 (1979–2017) MT 3 (1985–2006) MA 3 (2016–2025) WI 3 (2013–2013) DC 3 (2015–2017) MI 2 (2003–2017) NE 2 (1989–2002) OH 2 (1995–2000)

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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