State v. Adams, 254 P.3d 515

Adams was convicted in Kansas Supreme Court of first-degree felony murder predicated on felony child abuse after Shymire died from blunt-force trauma and immersion burns; she was home alone with two young children when injuries occurred.
The State relied on medical and law-enforcement witnesses; the defense argued injuries were accidental and exacerbated by Adams’ untrained resuscitation efforts.
Adams testified she was exhausted, abused by Turner, used drugs that day, and that she could not recall details; she described the bath incident and attempted CPR without training.
The district court gave a modified credibility/expert-witness instruction, adding language from civil expert-witness guidance to emphasize experts’ weight alongside other testimony.
During deliberations, jurors asked questions; the court provided a written response after consultation with counsel, with Adams not shown to be unequivocally excluded from the process, but the record does not clearly show her presence.
Adams moved for a new trial based on ineffective assistance of counsel; at an evidentiary hearing, trial counsel testified to reasons for strategy and omissions; the district court denied relief under Strickland.
Upon appeal, the Kansas Supreme Court affirmed Adams’ conviction, rejecting her claims of improper jury-question handling, improper witness-credibility instruction, and ineffective-assistance prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jury-question handling	Adams argues the court erred in responding to the question and summarized testimony instead of readback.	State contends Adams invited error; she participated in the process and agreed to the answer.	Invited-error doctrine applies; no reversal.
Witness credibility instruction	Adams asserts the hybrid expert instruction deviated from pattern and misemphasized experts.	State contends deviation was permissible and in context did not mislead the jury.	Instruction, viewed as a whole, accurately stated law; not reversible.
Ineffective assistance – Strickland	Adams claims trial counsel deficient and prejudicial; new trial should be granted.	State argues counsel acted within strategic discretion; no prejudice shown given strong State case.	Strickland standard not met; conviction affirmed.

State v. Hoge, 276 Kan. 801 (2003) (standard for reviewing jury-question responses)
State v. Moore, 274 Kan. 639 (2002) (jury-question procedure guidance)
State v. Betts, 272 Kan. 369 (2001) (presence during jury-question discussions; harmless-error analysis)
State v. Bruce, 255 Kan. 388 (1994) (invited-error doctrine application in jury-question response)
State v. Cramer, 17 Kan. App. 2d 623 (1992) (application of invited-error doctrine in appellate review)
State v. Bell, 266 Kan. 896 (1999) (presence and procedure considerations in jury-question context)
State v. Bolton, 274 Kan. 1 (2002) (presence during jury-question discussions; harmless error)
State v. Salton, 238 Kan. 835 (1986) (recordation of jury-question discussion requirements)
State v. Falke, 237 Kan. 668 (1985) (historic jury-question handling authorities)
State v. Reynolds, 230 Kan. 532 (1982) (early jurisprudence on jury questions and instructions)
State v. Willis, 240 Kan. 580 (1987) (credibility instruction considerations)
Gleason v. State, 277 Kan. 624 (2004) (assessment of trial counsel performance; Strickland framework context)
Chamberlain v. State, 236 Kan. 650 (1985) (Strickland prejudice standard applied)