knowing waiver (Kansas) · Go Syfert
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knowing waiver in Kansas

10 Kansas opinions name it 2 courts 1978–2026 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 (2)

CaseFollowedCited
State v. Dettmangreen
minn · 2006 · cited in 3 Kansas opinions naming this issue, 2024–2026
2 sentences

2026Although Nunez does not mention Duncan, its rationale reflects the need for a specific rather than general jury trial waiver of a fact that will enhance a defendant's sentence. 319 Kan. at 354 (quoting with favor State v. Dettman, 719 N.W.2d 644, 652 [Minn. 2006] ["'[A] defendant's admission of a fact supporting an upward sentencing departure [must] be accompanied by a knowing waiver of his right to a jury finding on that fact before the admission may be used to enhance his sentence.'"]); see State v. Contreras, 66 Kan.

2024And: "The Supreme Court's equation of sentencing factors with elements of an offense compels the conclusion that, just as a defendant's admission to an element of an offense cannot be used in lieu of a jury finding unless the defendant knowingly waives his right to a jury trial on that element, so too must a defendant's admission of a fact supporting an upward sentencing departure be accompanied by a knowing waiver of his right to a jury finding on that fact before the admission may be used to enhance his sentence." State v. Dettman, 719 N.W.2d 644, 652 (Minn. 2006).

33
United States v. Manuel Guerrero-Jassogreen
ca9 · 2014 · cited in 1 Kansas opinions naming this issue, 2024–2024
1 sentence

2024See United States v. Guerrero-Jasso, 752 F.3d 1186, 1192 (9th Cir. 2014) ("We treat defendant admissions as analogous to jury findings beyond a reasonable doubt for Apprendi purposes only when those admissions are made with knowledge of the penal consequences that attend those admissions."); State v. Dettman, 719 N.W.2d 644, 652 (Minn. 2006) ("[A] defendant's admission of a fact supporting an upward sentencing departure [must] be accompanied by a knowing waiver of his right to a jury finding on that fact before the admission may be used to enhance his sentence.").

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. Duncan green
kan · 2010
1 sentence

2026App. 2d 182 , 189, 579 P.3d 1278 (2025) ("The holding in Nunez teaches us this: Before a district court sentences a defendant to lifetime postrelease supervision for the conviction of a sexually violent crime, it should obtain a jury finding that the defendant was at least 18 years old when they committed the crime or, in the case of a plea, it should obtain a knowing and voluntary jury trial waiver that includes informing the defendant they are waiving the right to a jury finding on their age."). [1] 3 [1] In Duncan, the district court considered a fact that would support an upward durational

12026–2026
State v. Gillon green
kanctapp · 1999
1 sentence

2022The court found that "'knowingly'" only modified the possession element, while the barrel-length requirement only modified "'shotgun.'" Thus, the phrases were unconnected, and the knowing requirement did not apply to the barrel length. 25 Kan.

12022–2022
People v. Molnar green
ill · 2006
1 sentence

2020The court also pointed out that convicted sex offenders typically would be informed of their statutory duty to register and, therefore, would have 52 actual notice. 222 Ill. 2d at 513 .

12020–2020
State v. Antwine green
kanctapp · 1980
1 sentence

1996Antwine, 4 Kan.

11996–1996
State v. Nguyen green
kan · 1992
2 sentences

1993In State v. Nguyen, 251 Kan. at 75 , the Supreme Court stated the applicable standard of review, as quoted from State v. Zuniga: “When a trial court conducts a full . . . hearing on the admissibility of an extrajudicial statement by an accused, determines the statement was freely, voluntarily and knowingly given, and admits the statement into evidence at the trial, the appellate court should accept that determination if it is supported by substantial competent evidence.” In this case, the trial court held that the defendant’s statements were admissible because he had been fully informed of his

1993In State v. Nguyen, 251 Kan. at 75 , the Supreme Court stated the applicable standard of review, as quoted from State v. Zuniga: “When a trial court conducts a full . . . hearing on the admissibility of an extrajudicial statement by an accused, determines the statement was freely, voluntarily and knowingly given, and admits the statement into evidence at the trial, the appellate court should accept that determination if it is supported by substantial competent evidence.” In this case, the trial court held that the defendant’s statements were admissible because he had been fully informed of his

11993–1993
Boyce Motor Lines, Inc. v. United States green
scotus · 1952
1 sentence

1990Ed. 367 , 72 S. Ct. 329 (1952), a statute required drivers transporting explosives to avoid crowded thoroughfares “so far as practicable.” The United States Supreme Court concluded that the statute, which was enacted following extensive participation by the trucking industry in a process of suggesting drafts of the legislation, was not void for vagueness because it required a knowing violation.

11990–1990
Faretta v. California green
scotus · 1975
2 sentences

1989Faretta v. California, 422 U.S. 806, 835 , 45 L.

1989Faretta v. California, 422 U.S. 806, 835 , 45 L.

11989–1989
Massiah v. United States green
scotus · 1964
2 sentences

1978Our holding in this regard was based upon Massiah v. United States, 377 U.S. 201 , 12 L.Ed.2d 246 , 84 S.Ct. 1199 (1964).

1978Our holding in this regard was based upon Massiah v. United States, 377 U.S. 201 , 12 L.Ed.2d 246 , 84 S.Ct. 1199 (1964).

11978–1978

Statutes the citing opinions construe

KS § K.S.A. § 22-3717 (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

IL 153 (1966–2026) NY 128 (1965–2026) CA 86 (1972–2026) PA 74 (1969–2026) TX 60 (1970–2024) FL 54 (1981–2026) NJ 43 (1981–2025) LA 40 (1979–2020) OR 40 (1968–2025) IN 39 (1974–2025) MA 37 (1975–2024) MO 31 (1968–2025) TN 30 (1994–2020) WA 30 (1975–2025) AZ 29 (1976–2025) OH 27 (1984–2026) GA 26 (1978–2026) MI 22 (1976–2025) MD 22 (1971–2025) MN 22 (1985–2026) DE 19 (1978–2025) CT 17 (1985–2019) WI 17 (1979–2022) WV 16 (1995–2023) NC 15 (1983–2021) KS 10 (1978–2026) MS 9 (1992–2013) KY 9 (1987–2026) AL 9 (1984–2013) DC 8 (1971–2009) UT 7 (1988–2025) AR 7 (1979–2016) CO 7 (1984–2015) NV 7 (2011–2025) AK 6 (1980–2009) OK 5 (1969–2018) HI 5 (1982–2022) IA 5 (1985–2024) MT 4 (1988–2012) NH 4 (1980–2024) ND 4 (1996–2013) VT 4 (1983–2005) RI 4 (1996–2011) VA 3 (2013–2016) ID 3 (1987–2013) SC 2 (1976–2003) SD 2 (1919–1993) NE 2 (1970–2004) ME 2 (1994–2005)

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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