State v. Meeks, 339 P.3d 766

Meeks was convicted of second-degree intentional murder for shooting Wesley Smith in his home.
Meeks claimed battered woman syndrome caused by years of abuse and sought to introduce that theory at trial.
Before trial, Meeks sought a Hutchinson evaluation to assess state of mind; the court allowed it, noting admissibility depended on theory of defense.
The district court excluded Hutchinson's testimony as not tied to a self-defense claim; it also limited evidence of Smith's prior acts.
Court of Appeals affirmed; Kansas Supreme Court granted review to consider whether Meeks could pursue a self-defense claim based on battered woman syndrome.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Right to present a defense under inclusion of battered woman syndrome	Meeks asserts exclusion violated right to present defense.	State contends no self-defense claim was asserted; evidence irrelevant.	No violation; theory unasserted.
Whether appellate analysis of self-defense viability was proper	Meeks contends panel should assess if facts could support self-defense if asserted.	State dispute over necessity of such analysis.	Court disapproved of that analysis; moot without remand.
Admissibility of specific acts of prior violence by Smith	Evidence of Smith's prior acts would illuminate perceived danger under battered woman syndrome.	Without self-defense, prior acts are irrelevant.	Exclusion affirmed as issue moot; not remanded for new trial.

State v. Walters, 284 Kan. 1 (2007) (right to present defense subject to evidentiary rules)
State v. Cooperwood, 282 Kan. 572 (2006) (fundamental right to a fair trial; evidentiary limits)
State v. Hodges, 239 Kan. 63 (1986) (battered woman syndrome admissibility context)
State v. Stewart, 243 Kan. 639 (1988) (self-defense limitations in battered woman context)
State v. Kelly, 298 Kan. 965 (2014) (claims not raised at trial cannot be raised on appeal)
State v. Verser, 299 Kan. 776 (2014) (litigant may not invite error, then complain of that error on appeal)