State v. Gibson, 299 Kan. 207

Gibson (17 at the time) was interviewed by detectives about a drug-related homicide; he gave two inculpatory statements (Oct. 12 and Oct. 14, 2008) after initially going to the station voluntarily.
During the first interview Gibson admitted involvement; detectives then administered Miranda warnings and obtained a signed waiver and a recorded statement later that evening.
Detective testimony at the Jackson v. Denno hearing described Gibson as cooperative, polite, not obviously under the influence, and able to read and waive rights; the State introduced waiver forms and video transcripts.
The district court admitted both statements as voluntary without detailed on-the-record factor-by-factor findings; defense declined to call witnesses at the initial hearing and later moved to reconsider, asserting marijuana use, age, and intimidation rendered the statements involuntary.
The court denied the motion to reconsider, refused to reopen the evidentiary record or allow Gibson to testify about voluntariness, and Gibson was convicted of first-degree murder and aggravated robbery.

Issue	Plaintiff's Argument (Gibson)	Defendant's Argument (State)	Held
Whether district court erred by failing to make detailed findings that Gibson’s statements were voluntary	Court needed to make explicit factfindings or record was insufficient to support voluntariness (marijuana, youth, intimidation)	Record (detective testimony, signed waivers, videos) was sufficient; defendant did not preserve a need for more findings and counsel conceded voluntariness earlier	Court held record was sufficient; no remand needed — statements voluntary under totality of circumstances
Whether court abused discretion by refusing to let Gibson testify or reopen suppression hearing on reconsideration (claimed structural error)	Right to testify is fundamental; denying Gibson opportunity to testify on reconsideration was structural error requiring reversal	Reopening suppression hearings is discretionary; Gibson had opportunities earlier, defense offered no new evidence, and no authority establishes a right to reopen after foregoing testimony	Court held no structural error and no abuse of discretion in refusing to reopen or allow belated testimony; affirmed

Miranda v. Arizona, 384 U.S. 436 (establishes Miranda warnings requirement)
Jackson v. Denno, 378 U.S. 368 (criminal confession admissibility hearing standard)
State v. Bogguess, 293 Kan. 743 (State bears burden to prove voluntariness; defendant may testify at Denno hearing)
State v. Randolph, 297 Kan. 320 (totality-of-circumstances factors for voluntariness)
State v. Young, 220 Kan. 541 (juvenile-confession factors and heightened care)
State v. Ramos, 271 Kan. 520 (district court need not recite Young factors on record though best practice is to consider them)
State v. Miles, 233 Kan. 286 (no requirement to rehear motion to suppress decided on same facts)
Arizona v. Fulminante, 499 U.S. 279 (structural error framework)