State v. Qualls, 297 Kan. 61

Qualls was convicted of premeditated first-degree murder for shooting Beier during a bar fight in Topeka.
Qualls admitted to shooting but appealed, arguing insufficient evidence of premeditation, error for denying voluntary manslaughter instruction, and failure to instruct on self-defense.
The trial showed Beier both helped restrain and was involved in an altercation prior to the shooting; Qualls claimed Beier reached for a weapon.
Witnesses described Beier as physically imposing; admissible video footage captured the shooting but not the moments immediately before.
Eleven shell casings were found; Beier suffered multiple gunshot wounds with a complex trajectory; no weapon was found on Beier.
The jury was instructed on first-degree murder and second-degree murder; voluntary manslaughter instruction was denied; self-defense instruction was discussed but not given.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for premeditation	Qualls argues evidence insufficient for premeditation.	Qualls contends the record shows instantaneous reaction with no deliberation.	Sufficient evidence supported premeditation; remand on other grounds
Whether a voluntary manslaughter instruction should have been given	Qualls contends there was evidence supporting imperfect self-defense.	Qualls argues his subjective belief justified the instruction.	Instruction should have been given; error not harmless; remand for new trial
Self-defense instruction	Qualls sought self-defense instructions.	Qualls' theory overlapped with imperfect self-defense; the court did not rule on this due to remand.	Not decided on retrial

State v. McCaslin, 291 Kan. 697 (2011) (sufficiency review standard)
State v. Holmes, 278 Kan. 603 (2004) (premeditation deliberation inference)
State v. Scaife, 286 Kan. 614 (2008) (premeditation factors)
State v. Cosby, 293 Kan. 121 (2011) (deadly weapon alone not enough for premeditation)
State v. Gallegos, 286 Kan. 869 (2008) (voluntary manslaughter as lesser included offense)
State v. Ward, 292 Kan. 541 (2011) (harmless error standard for instructional error)
State v. Haberlein, 296 Kan. 195 (2012) (premeditation abundance discussion in context)
State v. Plummer, 295 Kan. 156 (2012) (instruction harmlessness framework)
State v. Backus, 295 Kan. 1003 (2012) (standard for lesser included offense instructions)
State v. Tahah, 293 Kan. 267 (2011) (subjective standard for imperfect self-defense)
State v. Ordway, 261 Kan. 776 (1997) (imperfect self-defense concept)
State v. Anderson, 287 Kan. 325 (2009) (defense theory sufficiency standard)