State v. Keaira Brown, 300 Kan. 542

Brown, age 13 at the time of the crimes, was tried as an adult after a district court waived juvenile jurisdiction and authorized adult prosecution.
She was convicted of first-degree felony murder and attempted aggravated robbery with a hard 20 life sentence for murder and a concurrent shorter sentence for the related offense.
The State sought and obtained authorization to prosecute Brown as an adult under the Revised Kansas Juvenile Justice Code, including eight factors for waiver.
Evidence at waiver included crime details, prior uncharged incidents, juvenile facility records, and testimony from various witnesses and experts.
The defense challenged the waiver ruling, the jury instruction on felony murder, the sufficiency of evidence, prosecutorial conduct, and the constitutionality of the harsh sentence for a juvenile.
The Supreme Court affirmed the district court’s waiver and the convictions, and upheld the mandatory hard 20 life sentence as constitutional under Miller and related precedents.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Waiver decision: proper application of eight factors	Brown argues district court abused discretion; lack of substantial evidence	State contends factors supported waiver	No abuse; factors supported waiver
Felony murder instruction: flight from aggravated robbery allowed	Instruction misstated law	Instruction was legally correct and factually appropriate	Instruction not error
Sufficiency of evidence for attempted aggravated robbery	No attempt evidence; taking occurred with death	Evidence showed attempt despite fatal taking	Sufficient evidence of attempted aggravated robbery
Prosecutorial misconduct in closing	Prosecutor improperly portrayed Brown's testimony as untruthful	Misconduct isolated and not reversible given overwhelming evidence	Mitigated; no reversible prejudice
Mandatory hard 20 life sentence for juvenile offender	Sentence unconstitutional as applied to juveniles under 18	Miller does not render hard 20 life unconstitutional here	Constitutional as applied; parole eligibility after 20 years under Kansas law

State v. Bailey, 292 Kan. 449 (2011) (factual review and standard for waiver decisions)
In re D.D.M., 291 Kan. 883 (2011) (abuse of discretion standard for waiver factors; substantial evidence requirement clarified)
State v. Griffin, 279 Kan. 634 (2005) (flight from attempting to commit an inherently dangerous felony included in felony murder instruction)
State v. Cheffen, 297 Kan. 689 (2013) (felony murder not alternate means doctrine; off-grid offenses clarified)
State v. Ward, 292 Kan. 541 (2011) (prosecutorial misconduct standard and harmlessness analysis)