State v. Enriquez, 266 P.3d 579

Enriquez was convicted of conspiracy to commit first‑degree murder and possession of cocaine with intent to sell.
Trejo‑Medrano and others plotted to kill Acosta to avoid debt for prior drug sales and to obtain more cocaine.
Cocaine and related paraphernalia were found in the Days Inn room and in a car trunk; a gun and bullets were found on Enriquez.
Trial court admitted evidence of prior drug activity and gave a drug‑evidence instruction patterned after PIK Crim.3d 67.13‑D.
Enriquez did not object or request a limiting instruction; the court did not provide a 60‑455 analysis or a limiting instruction.
Court analyzed whether the 60‑455 framework and lack of limiting instruction were reversible, ultimately finding harmless error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Unanimity for conspiracy overt acts required	Enriquez argues multiple overt acts require unanimity on which act was proven	Prosecution argues acts are alternative means, not multiple acts	No unanimity instruction required; acts are alternative means for conspiracy.
Admissibility and limiting instruction for prior crimes evidence	36The court erred by admitting prior drug activity without 60‑455 analysis or limiting instruction	Harmless given overwhelming evidence	Error but harmless; conviction affirmed.

State v. Boggs, 287 Kan. 298 (2008) (60‑455 analysis required; prior crimes not automatic except with proper procedure)
State v. Gunby, 282 Kan. 39 (2006) (requires 60‑455 analysis and limiting instruction for 455 evidence)
State v. Garcia, 285 Kan. 1 (2007) (three‑prong test for admissibility of 60‑455 evidence; require limiting instruction)
State v. Voyles, 284 Kan. 239 (2007) (unanimity framework for multiple acts conspiracy cases)
State v. Hooker, 271 Kan. 52 (2001) (alternative means analysis; unanimity not required for alternative means)