State v. Cline, 283 P.3d 194

Cline was convicted of premeditated first-degree murder and sentenced to life without parole for 25 years.
Gutierrez was shot on Sept. 21, 2007; the rifle was found under Cline’s bed and the weapon had a heavy trigger pull.
Cline claimed PCP intoxication affected his perceptions and intent; witness Carter testified to multiple inconsistent stories.
The defense sought to introduce evidence that Cline completed tenth grade via special education, arguing it explained credibility issues.
The State admitted Cline’s waiver-of-rights form, but questioned education details; trial addressed Cline’s reading ability and PCP effects.
The court ruled on evidentiary issues surrounding education evidence and the admissibility/voluntariness of Cline’s confession statements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Evidentiary admissibility of special education evidence	Cline's tenth-grade education, especially via special ed, is relevant to credibility.	Evidence of special ed is mental-disease/defect evidence and should be excluded.	Court did not abuse discretion; special-ed evidence who provides credibility context could be admitted, but not labeled as 'special ed.'
Post-invocation statements in confession	Post-invocation statements should be allowed; they relate to the overall confession.	Statements after saying 'through talking' may be invocations and should be excluded.	Harmless error; remaining statements were repetition of prior disclosures and did not affect the verdict.
Application of harmless error standard			State must prove error did not affect substantial rights; the court held the error was harmless beyond a reasonable doubt.

State v. Oliver, 280 Kan. 681 (Kan. 2005) (expert testimony on confession credibility limited to what jurors would know; relevance to credibility of confession)
State v. Donesay, 265 Kan. 60 (Kan. 1998) (invocation of right to silence and post-invocation statements analyzed)
Ward v. State, 292 Kan. 541 (Kan. 2011) (harmless error standard for constitutional errors; burden on State to show no impact on outcome)
State v. Holmes, 278 Kan. 603 (Kan. 2004) (Miranda ambiguity and need for clarifying questions)