State v. Teal, 121454

KBI Agent Chris Farris recruited Joseph Byrd, a cooperating informant and Teal’s former son‑in‑law, to perform a controlled buy of methamphetamine in Parsons. Byrd had agreed to cooperate to avoid jail on unrelated charges.
Byrd communicated with a Facebook account under the name Sebastian Stewart (whose profile picture appeared to show Teal); Byrd told the agent he believed Teal operated that account.
During the purchase Byrd met a man who arrived on a motorcycle, spoke with him, and then moved into an alley; Byrd returned with meth and identified that man as Teal. Farris videoed the approach from a distance but could not see or identify the dealer in the alley.
Evidence at trial included Facebook message screenshots, a recorded Facebook Messenger call, Byrd’s hidden audio recording of the deal, and Farris’s distant video; Byrd testified he learned the Sebastian Stewart connection by “word of mouth” in the drug community.
The district court instructed the jury to view informant testimony with caution. The jury convicted Teal of distributing 1–3.5 grams of methamphetamine; Teal appealed challenging (1) sufficiency of evidence on identity and (2) admission of Byrd’s ‘‘word of mouth’’ statements as hearsay/prior bad‑act evidence.

Issue	State's Argument	Teal's Argument	Held
Sufficiency of evidence that Teal was the dealer	Evidence (Byrd ID, Facebook messages/call, Byrd’s hidden audio, and Farris’s surveillance) permitted a rational juror to find guilt beyond a reasonable doubt	Byrd was an unreliable, self‑interested informant and there was inadequate corroboration tying Teal to the Facebook account or motorcycle dealer	Conviction affirmed; viewed in light most favorable to the State, the evidence was sufficient and credibility/resolution of conflicts are for the jury (Chandler standard)
Admission of Byrd’s ‘‘word of mouth’’ statement that Teal ran the Sebastian Stewart account (hearsay/prior bad acts)	The statement was explanatory of Byrd’s belief and not offered as proof of a prior specific crime; admission did not affect the verdict	Statement was impermissible hearsay and/or inadmissible prior‑bad‑act evidence under K.S.A. 60‑455	Court found the remark was more reputation/belief than a specific prior act, not barred by 60‑455; even if erroneous, admission was harmless because Byrd also testified from direct contact and other evidence supported identity

State v. Chandler, 307 Kan. 657 (establishes sufficiency review: view evidence in light most favorable to the State; appellate court does not reweigh evidence)
State v. Brinklow, 288 Kan. 39 (uncorroborated testimony can sustain a conviction unless it is incredible or defies belief)
State v. Richmond, 289 Kan. 419 (distinguishes reputation/generalized statements from evidence of a specific prior act under K.S.A. 60‑455)