State v. Edwards, 299 Kan. 1008

Edwards, intoxicated and disruptive, was detained by police; hospital staff later treated him with Haldol and released him as sober.
Zenner, living in Wichita, was attacked in her townhouse when Edwards forced his way in seeking a phone and attacked her with a hammer.
During the assault Edwards wrestled Zenner’s phone and hammer, leading to violent blows to her head and a struggle over the objects.
Police recovered Zenner’s phone with blood and Edwards’ wallet and hospital papers in nearby locations after the incident.
Edwards was charged with aggravated robbery, aggravated burglary, and attempted first-degree murder; trial history included multiple mistrials before conviction on aggravated robbery at a third trial.
The Court of Appeals affirmed the aggravated robbery conviction; the Supreme Court granted review to address issues of statutory interpretation and expert witness disclosure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the taking of Zenner's phone and hammer fits robbery</Issue	Edwards argues taking was incidental to battery	State contends taking satisfies robbery elements	Taking is not required to be intentional, incidental taking suffices for robbery
Application of K.S.A. 60-226 civil discovery to criminal expert testimony</Issue	Defense cites 60-226 as requiring advance notice	State should not be bound by civil notice rules for rebuttal witnesses	Civil discovery rules do not apply to criminal expert witnesses; rebuttal notices are not required
Instruction on incidental taking and force timing</Issue	Montgomery should have required an incidental-taking instruction	Montgomery is not good law; omission not error given evidence	Montgomery rejected; no error in omitting incidental-taking instruction

State v. Pennington, 281 Kan. 426 (2006) (aggravated robbery requires only general intent)
State v. Poulos & Perez, 230 Kan. 512 (1982) (specific intent to permanently deprive not element of robbery)
State v. McDaniel & Owens, 228 Kan. 172 (1980) (aggravated robbery not a specific-intent crime; general intent)
State v. Rueckert, 221 Kan. 727 (1977) (aggravated robbery does not require specific intent; intoxication not defense)
State v. Kunellis, 276 Kan. 461 (2003) (robbery complete upon forcible taking; asportation not required)
State v. Lucas, 221 Kan. 88 (1976) (robbery not require ownership of property by victim; differs from theft)
State v. Littlejohn, 298 Kan. 632 (2014) (aggravated robbery contains no alternative-taking-from-presence language)
State v. Drach, 268 Kan. 636 (2000) (rebuttal witnesses not required to be disclosed in advance)