State v. Edwards
243 P.3d 683
| Kan. | 2010Background
- Edwards was convicted of felony murder and attempted aggravated robbery for the Bagsby incident; Toliver testified under a plea deal.
- Edwards initially denied involvement, then admitted presence at the Bagsby residence during the attempted robbery.
- COMCARE competency evaluation was ordered June 18, 2007; report dated August 6; competency found August 10; trial tentatively set for October 1, 2007.
- Speedy-trial clock began March 7, 2007; delays occurred from April 30 to June 18 and from June 18 onward due to competency proceedings.
- District court denied discharge for speedy-trial violation, ultimately applying a court-ordered continuance under K.S.A. 22-3402(5)(b) and timing allowed under 90 days from competency finding.
- Appeal challenges speedy-trial computation, suppression of statements, aiding-and-abetting instruction, admission of photographs, limiting instruction on 60-455 evidence, and cumulative error; conviction affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Speedy-trial discharge standard | Edwards argues 90-day discharge due to State delay | State argues timely under (5)(b)/(5)(d) | Timely under (5)(b); discharge denied |
| Voluntariness of custodial statements | Edwards contends bipolar disorder and deprivation render statements involuntary | District court properly found statements voluntary | Statements voluntary; suppression denied |
| Aiding and abetting instruction | Requests added language: mere association insufficient | Pattern instruction suffices; no reversible error | No reversible error; pattern instruction adequate |
| Limiting instruction on 60-455 evidence | Limiting instruction included disputed/improper facts | Instruction reasonably limited prejudicial use | Not reversible error; harmless |
| Admission of photographs | Five photos are overly prejudicial with minimal probative value | Photos helpful to understand forensic testimony; not unduly prejudicial | Photographs admissible; not reversible error |
Key Cases Cited
- State v. Vaughn, 288 Kan. 140 (2009) (speedy-trial computation requires interpretation by appellate court)
- State v. Mitchell, 285 Kan. 1070 (2008) (statutory speedy-trial analysis framework)
- State v. Adams, 283 Kan. 365 (2007) (State bears responsibility to provide speedy trial)
- State v. Brown, 283 Kan. 658 (2007) (defense-motion delay timing start for speedy-trial purposes)
- State v. Rodriguez-Garcia, 27 Kan. App. 2d 439 (1999) (crowded-docket continuance interpretation guidance)
- State v. Hickles, 261 Kan. 74 (1996) (use of photographs to prove elements of crime is admissible)
- State v. Nash, 281 Kan. 600 (2006) (appeals may affirm for correct result on wrong theory)
- State v. Sappington, 285 Kan. 176 (2007) (photographic evidence authority and prejudicial-use standards)