State v. Longstaff, 299 P.3d 268

Longstaff challenged convictions for two counts of rape of a child under 14 and one count of aggravated indecent liberties with a child involving his granddaughters.
Evidence included a prior 1989 conviction for attempted aggravated incest of his daughter and a redacted videotaped interview with detectives.
District court admitted the prior-conviction evidence under K.S.A. 60-455 to show plan, among other purposes, and admitted the videotape.
Lisa, Longstaff’s daughter, testified about prior abuse; three granddaughters testified about being touched.
Nurse examinations of the victims showed injuries consistent with sexual abuse; the videotape included detectives commenting on credibility.
Court of Appeals affirmed; Longstaff sought Supreme Court review on 2 issues: 60-455 evidence and the videotape.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of 60-455 evidence to show plan	Longstaff—evidence not strikingly similar; not probative of plan	State—evidence shows plan by similar method	District court abused; evidence not strikingly similar; admission was improper but harmless
Harmlessness of 60-455 error	Prejudicial error undermines credibility of victims	Other strong evidence supported guilt	Harmless error given physical evidence, admissions, and limiting instruction
Videotaped interview admissibility and reliance on credibility comments	Detectives’ credibility remarks violated Elnicki	Record on appeal did not include the video; merits not reached	Merits not reached; issue waived due to record and procedural posture

State v. Torres, 294 Kan. 135 (2012) (three-part test for 60-455 admissibility; balancing of probative value and prejudice)
State v. Prine, 287 Kan. 713 (2009) (signature standard for strikingly similar plan evidence; abuse of discretion if not met)
State v. Damewood, 245 Kan. 678 (1989) (admissibility of prior crimes for plan due to pattern similarities)
State v. Overton, 279 Kan. 547 (2005) (strikingly similar pattern with multiple factors; not all similarities suffice)
Inkelaar, 293 Kan. 414 (2011) (admissibility standards and preservation principles for 60-455)