State v. Haygood, 430 P.3d 11

Background

Defendant Donald Haygood shot and killed Demetria Mills in the house he shared with his girlfriend Georgie Stallings and her son; Haygood admitted the shooting but disputed the circumstances, claiming he acted in self-defense because Mills rushed him with a knife.
Stallings and the State presented evidence of a recent domestic-violence incident in which Haygood punched Stallings, causing a swollen lip; the trial court admitted that prior-act evidence under K.S.A. 2017 Supp. 60-455 for motive, corroboration, and relationship context.
Eyewitness testimony from Stallings and her son contradicted Haygood’s account: neither saw Mills threaten or rush Haygood with a knife; a knife was found in the sink, but the coroner testified Mills died instantly and could not have moved after the shot. Ballistics tied the .40 caliber gun found at Haygood’s sister’s house to the fatal bullet.
The trial court denied Haygood’s requested jury instruction on self-defense and on involuntary manslaughter (imperfect self-defense), but gave imperfect self-defense as voluntary manslaughter; the jury convicted Haygood of premeditated first-degree murder and firearm possession by a felon. Haygood appealed.
On appeal, Haygood challenged (1) admission of prior domestic-violence evidence under K.S.A. 60-455, (2) prosecutorial misconduct in closing argument, and (3) the denial of self-defense and involuntary manslaughter instructions.

Issues

Issue	State's Argument	Haygood's Argument	Held
Admissibility of prior domestic-violence evidence under K.S.A. 60-455	Prior act was relevant to motive (victim might call police because she knew Haygood had beaten Stallings), corroboration, and relationship context; probative value outweighed prejudice	Evidence was propensity evidence, not relevant to any material fact; highly prejudicial	Affirmed: evidence admissible to show motive; trial court did not abuse discretion in admission or limiting instruction
Prosecutorial error in closing (misstating facts/law, arguing facts not in evidence, shifting burden, attacking credibility)	Prosecutor’s remarks were reasonable inferences from evidence, applied law correctly in context, did not shift burden, and merely attacked credibility based on record	Prosecutor misstated law/facts, argued facts not in evidence, shifted burden to defendant, and impermissibly called defendant a liar	No reversible error: comments fell within permissible advocacy; no prosecutorial error requiring Chapman analysis
Denial of requested perfect self-defense instruction	Evidence undermined defendant’s version (contradictory eyewitness and physical evidence); no objective basis for a reasonable belief in necessity of deadly force	Haygood’s testimony that Mills charged him with a knife constituted competent evidence entitling him to an instruction under K.S.A. 21-5108(c)	Reversed on error of law but harmless: district court erred in refusing instruction (defendant’s testimony was competent evidence), but State proved beyond reasonable doubt the verdict would not have changed
Denial of involuntary manslaughter (imperfect self-defense) lesser-included instruction	Evidence overwhelmingly supported premeditation; giving instruction would not have changed outcome	Defendant entitled to lesser-included instruction because his version could support involuntary manslaughter theory	Even if error, harmless: no reasonable possibility instruction would have led to conviction of lesser offense; conviction affirmed

Key Cases Cited

State v. Richard, 300 Kan. 715 (2014) (governs admission of other-crimes evidence under K.S.A. 60-455)
State v. Gunby, 282 Kan. 39 (2006) (three-part test for admitting other-crimes evidence under K.S.A. 60-455)
Chapman v. California, 386 U.S. 18 (1967) (harmless-error standard for constitutional claims)
State v. Reid, 286 Kan. 494 (2008) (motive can be admitted as highly persuasive circumstantial evidence)
State v. Sherman, 305 Kan. 88 (2016) (two-step prosecutorial error review: latitude then Chapman harmlessness)
State v. Bernhardt, 304 Kan. 460 (2016) (discusses premeditation factors and jury instruction standards)