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