State v. Coleman, 543 P.3d 61

Darnell D. Coleman was convicted of first-degree premeditated murder for the shooting death of Tamsen Kayzer, with whom he had a tumultuous and abusive relationship.
Kayzer was found shot five times in a rural area. Evidence included history of abuse, jealous confrontations, cell phone data linking Coleman to the scene, and attempts to delete incriminating social media messages.
At trial, Coleman's defense attempted to explain incriminating evidence and challenged the State's case, including premeditation and the prosecution's closing arguments.
Coleman appealed his conviction on four grounds: prosecutorial error in closing argument, inadequate jury instructions on premeditation, denial of motion to substitute counsel, and cumulative error.
The Kansas Supreme Court found prosecutorial error in misstating the law on premeditation during closing but determined these errors were harmless given the evidence and jury instructions on the law.

Issue	Plaintiff's (Coleman's) Argument	Defendant's (State's) Argument	Held
Prosecutorial Error in Closing	Prosecutors misstated law on premeditation, misleading the jury	Arguments fell within permissible latitude or were harmless given instructions	Prosecutorial error occurred, but harmless, conviction stands
Jury Instruction on Premeditation	Judge erred by using standard instruction, not expanded one	Standard instruction was legally sufficient and not misleading	No error in jury instructions
Denial of Substitution of Counsel	Judge should have replaced counsel due to communication breakdown	No complete breakdown warranting new counsel; no impairment to defense	No abuse of discretion in denying new counsel
Cumulative Error	Combined errors deprived him of fair trial	Only prosecutorial error identified, no cumulative prejudice	No cumulative error justifying reversal

Chapman v. California, 386 U.S. 18 (constitutional error harmless if no reasonable possibility it affected verdict)
State v. Bernhardt, 304 Kan. 460 (approved expanded language for premeditation jury instruction)
State v. Stanley, 312 Kan. 557 (discussed best practices for premeditation jury instructions)
State v. Hilyard, 316 Kan. 326 (pattern premeditation instruction sufficient absent misleading evidence or special facts)
State v. Sherman, 305 Kan. 88 (set standard for prosecutorial error—State must prove error harmless beyond reasonable doubt)
State v. Brown, 316 Kan. 154 (weighing the strength of evidence and proper jury instructions on harmless error review)