State v. Liles, 490 P.3d 1206

Three people (Davis, Fisher, Leavitt) were murdered in March 2017 at Liles' home; Liles was indicted and convicted on multiple counts including three counts of felony murder and related crimes.
Two witnesses (Shane Mays and Richard Folsom) testified for the State after reaching/negotiating benefits; the district court gave a standard accomplice instruction telling jurors to ‘consider with caution’ accomplice testimony.
During rebuttal closing, the prosecutor argued the same reasons supporting caution for accomplices also applied to Liles when assessing her credibility.
Liles requested a modified jury instruction explicitly cautioning about witnesses who testify for benefits; the court refused and told counsel to address credibility in argument.
Liles was sentenced to consecutive heavy terms (including three hard 25s); she later claimed the State breached an unwritten postconviction agreement to recommend a favorable sentence in exchange for her cooperation/testimony.

Issue	Plaintiff's Argument (Liles)	Defendant's Argument (State)	Held
Prosecutorial misstatement in closing	Prosecutor improperly told jurors to apply accomplice caution to Liles, misstating law and singling her out	Prosecutor permissibly argued witness bias and compared credibility based on evidence; did not legally apply instruction to Liles	No error — argument fell within permissible credibility commentary and was evidence-based
Jury instruction modification (informant/cooperating-witness caution)	Court should have instructed jury to view testimony of State-benefited witnesses with explicit caution	Such informant instruction applies only where witness acted as agent of the State in obtaining evidence; not required for noninformant cooperators; jurors already knew about benefits	No error — Dean controls; court not required to give modified cautionary instruction
Cumulative error	Combined effect of prosecutor comment + instruction refusal violated fair trial rights	Neither individual claim has merit, so no cumulative harm exists	No cumulative error because underlying claims fail
Alleged breach of postconviction sentencing agreement	State breached an unwritten promise to recommend leniency for Liles in exchange for postconviction testimony; seek resentencing	No developed record of any agreement; terms not specified; claim not preserved; Liles did not meet burden to show breach	Not reached on merits — record inadequate for appellate review; claim fails for lack of proof

State v. Vonachen, 312 Kan. 451 (standard for prosecutorial-error review)
State v. Haygood, 308 Kan. 1387 (limits on accusing defendant of lying in argument)
State v. Dean, 310 Kan. 848 (no legal requirement to instruct caution for noninformant cooperating witnesses)
State v. Ashley, 306 Kan. 642 (informant instruction limited to state-agent witnesses)
State v. Plummer, 295 Kan. 156 (when legally appropriate and factually supported, certain instructions must be given — distinguished here)
State v. Urista, 296 Kan. 576 (plea-agreement breach standards and remedies)
Santobello v. New York, 404 U.S. 257 (prosecutorial promise in plea context must be honored)
In re Care and Treatment of Quillen, 312 Kan. 841 (review instructions as a whole to assess potential juror confusion)