unified defense (Kansas) · Go Syfert
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unified defense in Kansas

12 Kansas opinions name it 2 courts 2007–2026 6 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. Voylesgreen
kan · 2007 · cited in 8 Kansas opinions naming this issue, 2013–2026
2 sentences

2026See State v. King, 299 Kan. 372, 382 , 323 P.3d 1277 (2014). "[I]n one of its purest forms," a unified defense is merely a "credibility contest between the victims and the alleged perpetrator." Voyles, 284 Kan. at 253 .

2026An offender's use of a unified defense can be "an important and compelling factor in firmly convincing the reviewing court that the jury would have reached a different verdict had the instruction error not occurred." State v. Trujillo, 296 Kan. 625, 631 , 294 P.3d 281 (2013). "'Kansas appellate courts have held [that] a "failure to instruct" in multiple acts cases [is] reversible error except when the defendant presents a unified defense, e.g., a general denial.'" De La Torre, 300 Kan. at 599 (quoting Voyles, 284 Kan. at 253 ). 18 The record before us reflects that Williams generally denied an

38
State v. Trujillogreen
kan · 2013 · cited in 4 Kansas opinions naming this issue, 2013–2026
2 sentences

2026An offender's use of a unified defense can be "an important and compelling factor in firmly convincing the reviewing court that the jury would have reached a different verdict had the instruction error not occurred." State v. Trujillo, 296 Kan. 625, 631 , 294 P.3d 281 (2013). "'Kansas appellate courts have held [that] a "failure to instruct" in multiple acts cases [is] reversible error except when the defendant presents a unified defense, e.g., a general denial.'" De La Torre, 300 Kan. at 599 (quoting Voyles, 284 Kan. at 253 ). 18 The record before us reflects that Williams generally denied an

2026An offender's use of a unified defense can be "an important and compelling factor in firmly convincing the reviewing court that the jury would have reached a different verdict had the instruction error not occurred." State v. Trujillo, 296 Kan. 625, 631 , 294 P.3d 281 (2013). "'Kansas appellate courts have held [that] a "failure to instruct" in multiple acts cases [is] reversible error except when the defendant presents a unified defense, e.g., a general denial.'" De La Torre, 300 Kan. at 599 (quoting Voyles, 284 Kan. at 253 ). 18 The record before us reflects that Williams generally denied an

24
State v. Kinggreen
kan · 2013 · cited in 3 Kansas opinions naming this issue, 2014–2024
2 sentences

2014Inconsistent testimony from a victim, for example, can mean reversal is necessary. 284 Kan. 239 , Syl. ¶ 5; see [Kameron] King, 297 Kan. at 983 (“presentation of a unified defense or a general denial does not foreclose reversible error in a multiple acts case”). “[W]hen other evidence presents inconsis tencies that distinguish between two or more incidents,” a review of the entire record is appropriate “to determine if [the appellate court] is firmly convinced that the jury would have reached a different verdict had the error not occurred,” i.e., whether there was clear error. 297 Kan. at 983-

2014Inconsistent testimony from a victim, for example, can mean reversal is necessary. 284 Kan. 239 , Syl. ¶ 5; see [Kameron] King, 297 Kan. at 983 (“presentation of a unified defense or a general denial does not foreclose reversible error in a multiple acts case”). “[W]hen other evidence presents inconsis tencies that distinguish between two or more incidents,” a review of the entire record is appropriate “to determine if [the appellate court] is firmly convinced that the jury would have reached a different verdict had the error not occurred,” i.e., whether there was clear error. 297 Kan. at 983-

23
State v. De La Torregreen
kan · 2014 · cited in 3 Kansas opinions naming this issue, 2021–2026
2 sentences

2026An offender's use of a unified defense can be "an important and compelling factor in firmly convincing the reviewing court that the jury would have reached a different verdict had the instruction error not occurred." State v. Trujillo, 296 Kan. 625, 631 , 294 P.3d 281 (2013). "'Kansas appellate courts have held [that] a "failure to instruct" in multiple acts cases [is] reversible error except when the defendant presents a unified defense, e.g., a general denial.'" De La Torre, 300 Kan. at 599 (quoting Voyles, 284 Kan. at 253 ). 18 The record before us reflects that Williams generally denied an

2021The court then pointed out that the defendant had not presented a unified defense because some jurors could have found the defendant only intentionally caused the older bruising while other jurors could have found he only intentionally caused the injuries on September 6. 300 Kan. at 600 .

13
State v. Kinggreen
kan · 2014 · cited in 1 Kansas opinions naming this issue, 2026–2026
2 sentences

2026See State v. King, 299 Kan. 372, 382 , 323 P.3d 1277 (2014). "[I]n one of its purest forms," a unified defense is merely a "credibility contest between the victims and the alleged perpetrator." Voyles, 284 Kan. at 253 .

2026See State v. King, 299 Kan. 372, 382 , 323 P.3d 1277 (2014). "[I]n one of its purest forms," a unified defense is merely a "credibility contest between the victims and the alleged perpetrator." Voyles, 284 Kan. at 253 .

11
State v. Torresgreen
kan · 2005 · cited in 1 Kansas opinions naming this issue, 2007–2007
2 sentences

2007See Torres, 280 Kan. at 321-22 , 121 P.3d 429 .

2007See Torres, 280 Kan. at 321-22 , 121 P.3d 429 .

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 (1)

CaseCitedYears
State v. Voyles green
kanctapp · 2005
2 sentences

2007We respectfully conclude that in multiple acts cases, controlling case law requires that if, as here, it is determined that factually separate incidents have been alleged, failure to give a unanimity instruction must be deemed harmless if the defendant has presented a unified defense to all of those acts." (Emphasis added.) 34 Kan.App.2d at 116 , 116 P.3d 720 .

2007We respectfully conclude that in multiple acts cases, controlling case law requires that if, as here, it is determined that factually separate incidents have been alleged, failure to give a unanimity instruction must be deemed harmless if the defendant has presented a unified defense to all of those acts." (Emphasis added.) 34 Kan.App.2d at 116 , 116 P.3d 720 .

12007–2007

Statutes the citing opinions construe

KS § K.S.A. § 22-3421 (6) KS § K.S.A. § 22-3423 (4) KS § K.S.A. § 60-261 (4) KS § K.S.A. § 20-3018 (3) KS § K.S.A. § 21-5506 (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

CA 217 (1987–2026) CT 13 (1991–2025) KS 12 (2007–2026) IL 8 (1996–2020) NY 6 (1985–2025) GA 6 (1969–2021) FL 5 (1983–2010) DE 4 (2010–2023) MA 4 (2011–2025) TX 4 (2010–2019) OK 4 (2004–2006) ID 3 (1987–2011) NH 3 (1972–1993) DC 3 (1974–1988) OR 3 (1992–2025) WI 3 (1992–2005) WA 2 (1986–2015) ME 2 (1980–1989) MN 2 (2017–2026) NM 2 (2017–2017)

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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