State v. Huddleston, 298 Kan. 941

Huddleston was convicted of premeditated first-degree murder for Todd Stover’s 2000 death.
Two prosecutors argued premeditation could occur after the killing, which the court found to be misstatements of law.
The trial admitted two jailhouse letters Huddleston wrote to her sister, implicating her in the death and shifting blame.
Evidence included Huddleston’s statements to police, her plan to kill Stover with insulin, and her actions before, during, and after the killing.
The court held the misstatements were harmless under Tosh and upheld the conviction, and also held the jailhouse letters admissible as probative of consciousness of guilt and intent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was prosecutorial misconduct reversible?	Huddleston	Huddleston	No reversible error; misconduct was harmless
Are the jailhouse letters admissible and probative?	Huddleston	Huddleston	Admissible; letters probative of intent/consciousness of guilt outweigh prejudice

State v. Henry, 273 Kan. 608 (2002) (misstated law considered with jury instructions and other error)
State v. Moncla, 262 Kan. 58 (1997) (misstatements evaluated under harmless error framework)
State v. Tosh, 278 Kan. 83 (2004) (two-step prosecutorial-misconduct analysis; harmlessness under Tosh standard)
State v. Bridges, 297 Kan. 989 (2013) (dual harmlessness standard; constitutional and statutory harmlessness applied)
State v. Herbel, 296 Kan. 1101 (2013) (distinguishes程度 of harmlessness for constitutional error)