State v. Littlejohn, 298 Kan. 632

Littlejohn convicted by jury of felony murder, aggravated robbery, aggravated kidnapping, and aggravated assault; sentenced to hard 20 life plus 277 months consecutive.
State alleged felony murder based on inherently dangerous felonies (aggravated robbery/kidnapping) and presented multiple acts.
Defense testified Bogguess forced Littlejohn to participate; Littlejohn claimed innocence or coercion.
Police Mirandized Littlejohn; he made statements later admitted after DNA/shoe evidence tied him to crimes.
Defective charging: each count alleged alternative means; no bill of particulars filed; no arrest judgment.
Court affirmed convictions after addressing jury instructions, suppression motion, charging sufficiency, and cumulative error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Unanimity instruction for felony murder required?	State objected; plural underlying felonies are alternative means	Littlejohn argues unanimity needed	No unanimity instruction required; single felony murder verdict supported by record
Second-degree murder lesser-included instructions	Defendant failed to request; error review	Unclear if legally/factually appropriate	Both instructions legally appropriate; not clearly erroneous to omit based on record
Aiding/abetting instruction sufficiency	Pattern instruction lacked extra language	Juries infer intent from standard aiding/abetting language	Language not clearly erroneous; better practice suggested but not reversible error
Compulsion defense instruction	Sought broader compulsion scope	Evidence supported compulsion theory	Instruction legally appropriate; fact-specific evidence supported compulsion applicability
Post-Miranda statements suppression (Lost-Miranda)	Motion to suppress; claim of involuntariness/coercion	Record insufficient to review due to missing DVD/transcript	Record inadequate for review; suppression affirmed/denied on record evidence without transcript

State v. Deal, 293 Kan. 872 (Kan. 2012) (definitional scope of second-degree murder; different forms of murder as lesser included offenses)
State v. Calvin, 279 Kan. 193 (Kan. 2005) (second-degree murder as lesser included offense of felony murder)
State v. Becker, 290 Kan. 842 (Kan. 2010) (aiding/abetting specific-intent requirements)
State v. Williams, 295 Kan. 506 (Kan. 2012) (preserves standard for review of instruction preservation under 22-3414(3))
State v. Ellmaker, 289 Kan. 1132 (Kan. 2009) (preservation and harm standard for instructional errors)
State v. Voyles, 284 Kan. 239 (Kan. 2007) (unanimity framework for multiple-acts cases)
State v. Jones, 295 Kan. 1050 (Kan. 2012) (unanimity when multiple acts could constitute the crime)
State v. Sanborn, 281 Kan. 568 (Kan. 2006) (unanimity concept in multiple-acts cases)
State v. Ransom, 288 Kan. 697 (Kan. 2009) (felony murder via inherently dangerous felonies)
State v. Saylor, 228 Kan. 498 (Kan. 1980) (electing alternative means in charging; sufficiency of charging)