State v. Crawford
300 Kan. 740
| Kan. | 2014Background
- Crawford challenges the Court of Appeals’ rulings on three prosecutorial misconduct claims and the standard applied to determine if a third instance denied a fair trial.
- S.V. alleged Crawford sexually assaulted her; forensic DNA from under her fingernails linked to Crawford; investigators found oil/vehicle evidence near the scene.
- Crawford was convicted of aggravated kidnapping, aggravated indecent liberties with a child under 14, and criminal threat; district court sentenced to 337 months.
- Court of Appeals affirmed; Crawford petitioned the Supreme Court for review limited to prosecutorial misconduct.
- Prosecutorial misconduct alleged: (A) voir dire intimidation, (B) closing remarks referencing facts not in evidence, (C) jigsaw puzzle analogy misstating burden of proof.
- Court affirming: the prosecutor’s conduct, including the jigsaw analogy, was ultimately harmless beyond reasonable doubt given the evidence and proper jury instructions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prosecutorial intimidation during voir dire violated due process | Crawford claims closing remarks referenced non-evidentiary facts | State argues remarks reflected testimony and inferences from evidence | No misconduct; reasonable inferences and testimony supported remarks. |
| Jigsaw puzzle analogy misstating burden of proof and denying fair trial | Crawford asserts the analogy distorted reasonable doubt and burden of proof | State maintains analogy violated warnings but did not cross line; case law warns against such analogies | Harmless beyond a reasonable doubt; evidence strong enough to sustain verdict despite misconduct. |
Key Cases Cited
- State v. Tosh, 278 Kan. 83 (2004) (prosecutorial misconduct standard; harmlessness two-step framework)
- State v. Ward, 292 Kan. 541 (2011) (clarified dual standards; same benchmark as Chapman and 60-261)
- Bridges v. State, 297 Kan. 989 (2013) (harmlessness framework for prosecutorial misconduct)
- Huddleston v. State, 298 Kan. 941 (2014) (proper jury instructions on burden of proof affecting misconduct impact)
- Stevenson v. State, 297 Kan. 49 (2013) ( Wheel of Fortune analogy warning; cautions on misusing reasonable doubt analogies)
- Magallanez, 290 Kan. 906 (2010) (warning against embellishing burden of proof; potential reversal when misstatements occur)
- Sappington, 285 Kan. 176 (2007) (discussed prior opinions on reasonable doubt in misconduct context)
- Chapman v. California, 386 U.S. 18 (1967) (harmlessness standard for federal constitutional error)