State v. Adams, 253 P.3d 5

Adams was convicted by a jury of premeditated first-degree murder under K.S.A. 21-3401(a) and criminal use of a weapon under K.S.A. 21-4201.
The shooting occurred after a bar dispute involving Adams, Jeff and Jake Litchenberger, Phanivong, and Inhnarath in Kansas City, Kansas, on December 23, 2007.
Witness accounts conflicted: trial testimony varied on who started the confrontation and whether a knife or other weapon was involved.
Adams testified he acted in self-defense, pulled a gun when threatened, and fired two shots, claiming he did not intend to kill.
The State argued Adams planned or escalated the violence and acted with premeditation, while defense emphasized self-defense and lack of intent to kill.
The Kansas Supreme Court affirmed the conviction, rejecting Adams’ challenges to prosecutorial conduct, jury instruction order, and the definitions of criminal intent and premeditation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there prosecutorial misconduct requiring reversal?	Adams claims multiple closing remarks misstate the law and inflame.	State contends comments were not plain error.	No reversible plain error; some remarks improper but not outcome-determinative.
Did the order of jury instructions violate the presumption of innocence?	Instructions on premeditation and lesser offenses were in descending order.	Pattern instructions permit this order.	No reversible error; instruction sequence aligned with precedent.
Did the criminal-intent and premeditation instructions impermissibly lessen the State's burden?	Inference instruction (No. 17) improperly shifts burden.	Given with other elements, it does not relieve the State.	No reversible error; instructions cumulatively properly stated the law.

State v. Albright, 283 Kan. 418 (2007) (plain error analysis and prosecutorial conduct standard)
State v. McReynolds, 288 Kan. 318 (2009) (two-step analysis for prosecutorial misconduct; harmless error considerations)
State v. Tosh, 278 Kan. 83 (2004) (prosecutorial error when misstatement of law affects fairness)
State v. Henry, 273 Kan. 608 (2002) (victim-impact comments can be reversible when inflaming passions)
State v. Donesay, 265 Kan. 60 (1998) (victim-impact testimony; relevance and prejudice standards)
Finley v. Cravatt (Finley II), 273 Kan. 237 (2002) (prosecutor not to let defendant escape responsibility; not misconduct here)
State v. Roberson, 272 Kan. 1143 (2002) (lesser-included offenses and instructional clarity; no coercion)
State v. Lawrence, 281 Kan. 1081 (2006) (approval of PIK pattern for ordering lesser offenses)
State v. Trujillo, 225 Kan. 320 (1979) (order of lesser offenses for orderly deliberation)
State v. Ellmaker, 289 Kan. 1132 (2009) (permissive inferences vs. required elements; due process)