State v. Edwards, 290 P.3d 661

Edwards was convicted of aggravated robbery; the trial focused on whether he used force while armed to take Zenner’s phone during the incident at her apartment.
Edwards argued involuntary intoxication due to Haldol administered at a hospital the night before, claiming akathisia affected his understanding of the wrongdoing.
The jury found Edwards guilty of aggravated robbery after a third trial; the first two trials ended in mistrials (attempted murder/aggravated burglary acquitted/ mistrial on aggravated robbery due to an in limine violation).
Dr. Goodman testified Edwards suffered akathisia from Haldol, potentially impairing his cognition; Dr. Rohrig rebutted, asserting such effects are rare from a single dose.
The court addressed multiple issues: sufficiency of evidence, jury instructions, admissibility of an expert, limiting defense testimony, ineffective assistance, and cumulative error (the court ultimately affirmed).
The State’s theory included taking Zenner’s phone by force while Edwards was armed with a hammer, leading to aggravated robbery under K.S.A. 21-3427.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for aggravated robbery	Edwards—insufficient evidence	State’s taking was pre/post-force issue	Sufficient evidence; force contemporaneous with taking/armed presence shown
Jury instruction on aggravated robbery	Montgomery requires incidental-taking caution	Thompson controls; no required incidental-taking instruction	No reversible error; Thompson controls; incidental-taking instruction not required
Admission of State’s expert (Dr. Rohrig)	Rohrig should have been disclosed; rebuttal witness rule did not apply	Rohrig proper rebuttal witness; no discovery obligation	No reversible error; proper use of rebuttal witness
Limitation of Edwards’ expert testimony	Evidence of mental illness and need for observation could illuminate state during incident	Limitation was within trial court discretion and not prejudicial	No abuse of discretion; testimony limited to involuntary intoxication effects
Ineffective assistance of counsel	Counsel failed to call witnesses and explore avenues	Strategic decisions after thorough investigation; no prejudice shown	No ineffective-assistance error; claims rejected

State v. Bateson, 266 Kan. 238 (1998) (Robbery requires force contemporaneous with taking; review evidence in light of State)
State v. Adam, 257 Kan. 693 (1995) (Affirmed that aggravated robbery is a general or require general intent; not to read specific intent to deprive)
State v. Thompson, 221 Kan. 165 (1976) (No specific intent to permanently deprive; taking by force/threat suffices)
State v. Montgomery, 26 Kan. App. 2d 346 (1999) (Held that intent to permanently deprive not required; incidental taking case questioned)
State v. Boyd, 46 Kan. App. 2d 945 (2011) (Taking from person vs presence not separate alternative means; single means)