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State v. Lloyd
299 Kan. 620
| Kan. | 2014
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Background

  • Chavira Brown, 17 months old, died and was found in the attic of Lloyd’s house; Lloyd lived with his girlfriend Loudermilk and their infant son.
  • Lloyd was charged with first-degree premeditated murder, felony murder (under child abuse), and child abuse; Loudermilk testified against him; detectives interrogated Loudermilk, whose statements and trial testimony were central to the case.
  • Police discovered Chavira’s body in a knotted trash-bag‑inside-sofa-cover attic concealment after Loudermilk’s statements corrupted by interrogation tactics.
  • Lloyd challenged the admission of Loudermilk’s statements and sought to strike her pretrial statement/testimony as coerced; the district court denied the motion to strike.
  • The jury convicted Lloyd of both first-degree murder theories and child abuse; the district court imposed a hard 50 life sentence based on two aggravating factors; Alleyne and Soto later required vacatur of the hard 50, and remand for resentencing.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the trial court erred by denying the motion to strike coerced witness statements Lloyd asserts due process violation from coerced statements Lloyd contends coercion taints Loudermilk’s testimony and pretrial statements No reversible error; the motion was untimely and the court did not abuse discretion
Sufficiency of evidence for premeditated first-degree murder State argues sufficient evidence of premeditation exists Lloyd argues evidence fails to prove premeditated intent Sufficient evidence supported premeditation beyond reasonable doubt
Admission of prior crime evidence under K.S.A. 2009 Supp. 60-455 State contends prior shooting testimony is admissible to prove credibility and motive Lloyd argues undue prejudice and lack of material relevance; insufficient limiting instruction District court did not err; evidence admissible as credibility/credibility-related material under 60-455
Constitutionality of hard 50 sentencing under Alleyne and retroactivity on resentencing State argues statute not unconstitutional; cites continued applicability Alleyne makes hard 50 unconstitutional; Soto requires retroactive reconsideration Hard 50 sentence unconstitutional under Alleyne/Soto; vacated and remanded for resentencing

Key Cases Cited

  • State v. Daniels, 278 Kan. 53 (2004) (coerced witness statements can implicate due process)
  • State v. Chanthaseng, 293 Kan. 140 (2011) (objections to evidence must be specific and timely)
  • State v. Roach, 223 Kan. 732 (1978) (timeliness of motions to strike evidence post‑trial)
  • State v. Cook, 286 Kan. 1098 (2008) (premeditation factors may be inferred from circumstances)
  • State v. Gunby, 282 Kan. 39 (2006) (60-455 materiality and probative value analysis; credibility evidence)
  • State v. Soto, 299 Kan. 102 (2014) (Alleyne applied to hard 50; remand for resentencing)
  • State v. Williams, 229 Kan. 646 (1981) (inference stacking and sufficiency review principles)
Read the full case

Case Details

Case Name: State v. Lloyd
Court Name: Supreme Court of Kansas
Date Published: May 30, 2014
Citation: 299 Kan. 620
Docket Number: No. 104,392
Court Abbreviation: Kan.