State v. Bridges, 297 Kan. 989

Bridges was convicted of unintentional reckless second-degree murder for the July 15, 2004 explosion at his home.
Investigators concluded a gas valve was left on, allowing gas to fill the house before an explosion killed his fiancée.
Bridges gave varying explanations; the State theorized insurance fraud as motive, potentially to obtain proceeds.
District court excluded Bridges’ proposed depression expert and a portion of insurance-proceeds evidence at trial.
Bridges challenged statements to investigators and alleged prosecutorial misconduct in closing argument; the Court of Appeals affirmed the conviction.
Supreme Court granted review to address admissibility, Miranda issues, prosecutorial conduct, and sentencing doctrine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of depression and proceeds evidence	Bridges argues depression evidence is probative; proceeds show lack of motive.	Bridges contends exclusion violated his theory of defense and discovery rules.	Evidence exclusion affirmed; not probative or untimely but harmless.
suppression of Bridges' statements	Bridges claims Miranda rights were violated in multiple interviews.	State contends interviews were non-custodial or properly warned and waived.	District court's denial of suppression upheld; warnings/waivers appropriate under totality of circumstances.
Preservation of credibility rulings	Witness comments on Bridges’ credibility violated rights.	State contends issue not preserved for appeal.	Not preserved for review; objection required.
Prosecutorial misconduct in closing	Prosecutor commented on Bridges’ credibility and misstated evidence.	State concedes some error but argues harmless.	Misconduct found but Harmless under Chapman and K.S.A. 60-261; cumulative harmless.
Identical offense sentencing doctrine	Bridges seeks involuntary manslaughter (lesser included) sentencing.	State argues doctrine does not apply to lesser included offenses in this context.	Doctrine inapplicable; proper to sentence for second-degree murder; involuntary manslaughter is a lesser included offense under Cheever.

State v. Edwards, 48 Kan. App. 2d 383, 290 P.3d 661 (2012) (expert testimony must be probative and material; discovery rules apply)
Gaona, 293 Kan. 930, 270 P.3d 1165 (2012) (discretion to exclude evidence for discovery violations)
State v. Ward, 292 Kan. 541, 256 P.3d 801 (2011) (harmlessness standards for prosecutorial error)
State v. Mattox, 280 Kan. 473, 124 P.3d 6 (2005) (totality of circumstances in Miranda waivers)
State v. Nguyen, 281 Kan. 702, 133 P.3d 1259 (2006) (timing of waivers and revocation risk factors)
State v. Warrior, 294 Kan. 484, 277 P.3d 1111 (2012) (custody factors in assessing Miranda rights)
State v. Swanigan, 279 Kan. 18, 106 P.3d 39 (2005) (standards for voluntariness of confessions)
State v. Reid, 286 Kan. 494, 186 P.3d 713 (2008) (probativity and relevance of evidence)
State v. Engelhardt, 280 Kan. 113, 119 P.3d 1148 (2005) (involuntary manslaughter as lesser included offense of murder)
State v. Cheever, 295 Kan. 229, 284 P.3d 1007 (2012) (degrees of homicide; involuntary manslaughter as lesser offense)
State v. Sandberg, 290 Kan. 980, 235 P.3d 476 (2010) (identical offense sentencing doctrine does not apply to lesser included offenses)
State v. Casady, unknown reporter (2009) (Board of Indigents’ Defense Services fees upheld)
Shadden, 290 Kan. 803, 235 P.3d 436 (2010) (two-pronged test for admissibility of evidence in limine)
Elkinson v. State, 279 Kan. 47, 105 P.3d 1222 (2005) (proving witness credibility and statements in trial)