State v. Marshall, 303 Kan. 438

Marshall was tried and convicted of capital murder for two 2012 killings inside a Wichita Dollar General; sentenced to life without parole (State did not seek death).
Surveillance and a latent palm print on the store entry door matched Marshall’s prints; he was arrested, waived Miranda, spoke with detectives, then invoked counsel.
While alone during booking, Marshall made rambling statements suggesting possible involvement but also denying memory of being at the store; those statements were recorded by an observing officer.
Marshall filed pro se motions: (1) seeking evaluation at Larned State Hospital and (2) seeking new counsel for alleged poor communication and conflict; he later withdrew the first motion and pursued the second but gave only vague, conclusory reasons at hearings.
Defense counsel had met Marshall repeatedly and affirmed Marshall was competent and that communication had not broken down; the court denied the competency request and refused to appoint new counsel after inquiry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Competency evaluation	Court properly found no bona fide doubt requiring sua sponte evaluation	Marshall: prior Larned commitment, meds, and booking-room statements raised bona fide doubt	Court: no abuse of discretion; pretrial and hearing behavior and counsel’s view refuted incompetency claim
Inquiry into request for new counsel	Court conducted sufficient inquiry and reasonably denied substitution	Marshall: court failed to sufficiently investigate his complaints about counsel	Held: no abuse; motions were vague, mostly withdrawn, and counsel showed adequate communication
Jury-instruction misstatement	State: transcript error; judge said "not guilty" and reporter omitted "not"	Marshall: judge misstated that he pled guilty during instructions	Court: amended transcript corrected omission; no error
Cumulative error	No cumulative prejudice because individual claims lack merit	Marshall: cumulative effect denied fair trial	Court: rejects cumulative-error claim; no underlying errors proved

State v. Foster, 290 Kan. 696 (addresses abuse of discretion on competency review)
State v. Mosher, 299 Kan. 1 (definition of judicial abuse of discretion)
Dusky v. United States, 362 U.S. 402 (test for competency to stand trial)
State v. Barnes, 293 Kan. 240 (presumption of competency)
State v. Pfannenstiel, 302 Kan. 747 (duty to inquire about conflict and sufficiency of inquiry)
State v. Bryant, 285 Kan. 970 (standard for substitute counsel; "justifiable dissatisfaction")