State v. Burnett, 300 Kan. 419

Burnett was convicted of felony murder, criminal discharge of a firearm at an occupied dwelling, and criminal possession of a firearm.
He challenged evidentiary rulings including exclusion of other shootings, admission of letters, and denial of a continuance to redact a video interview.
The district court admitted certain letters Burnett sent to a witness; the State relied on third‑party evidence rules to exclude other shootings.
The State presented firearms evidence and a video/interview with Burnett; Burnett argued substitute counsel was warranted after alleged breakdown in communication.
On appeal, the court affirmed, finding one reversible error (precluding cross‑examination about other holes) and assumed another (lack of limiting instruction) was harmless, with overall no denial of a fair trial.
Additional review covered ineffective assistance claims and substitute counsel rulings, which were ultimately rejected.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of other shootings as third-party evidence	Burnett argues Ramsey’s house was a drug house and others shot there.	Burnett contends this shows another shooter and challenges investigators’ conclusions.	District court abused discretion; error harmless overall.
Continuance to redact video statement for cross-examination	Beaming cross-examination would be impaired without the video.	Continual delay violated confrontation rights.	No abuse of discretion; continuance denied.
Felony murder alternative means instruction	Instruction created alternative means requiring proof of multiple theories.	Cheffen rejects that language as separate means.	No error; statute not providing alternative means.
Admission of Burnett's letters to Dickson	Letters show intent and witness cooperation; probative.	Letters obtained via jail inspection violate Fourth Amendment.	District court properly admitted; no Fourth Amendment violation found.
Limiting instruction on other crimes evidence	Limiting instruction should have been given for other crimes/civil wrongs.	Evidence under 60-455 warranted limiting instruction.	Error not clearly erroneous; harmless.

State v. Marsh, 278 Kan. 520 (Kan. 2004) (third-party evidence requires showing connection to crime)
State v. Evans, 275 Kan. 261 (Kan. 2003) (defendant’s third-party evidence may be admissible to prove innocence)
State v. Inkelaar, 293 Kan. 414 (Kan. 2011) (district court’s third-party evidence ruling reviewed for abuse of discretion)
State v. Adams, 280 Kan. 494 (Kan. 2005) (no third-party evidence where no scene or link to crime)
State v. Matthews, 217 Kan. 654 (Kan. 1975) (outgoing jail mail copied; no reasonable expectation of privacy)
State v. Cheffen, 297 Kan. 689 (Kan. 2013) (felony murder statute does not create alternative means)
State v. Williams, 295 Kan. 506 (Kan. 2012) (instruction-preservation and clearly erroneous standard)