State v. Ward, 256 P.3d 801

Ward was convicted of 14 felonies related to four cocaine sales in Liberal, Kansas, arising from controlled buys by Candy Stinnett under police direction.
The purchases occurred at a laundromat within 1,000 feet of Garfield School and involved Ward, Broderick West, and Ward's daughter Jackson; Stinnett testified to the transactions and officers observed several aspects.
Stinnett cooperated with law enforcement in exchange for dismissal of her own charges, including drug-related offenses.
Detective Wagenseller testified that West and Jackson, wearing orange jail jumpsuits, were in the courtroom and identified as Ward's associates, prompting a mistrial motion by Ward's counsel.
The Court of Appeals affirmed the mistrial denial and the sufficiency of the evidence; Ward sought Supreme Court review, which addressed the mistrial standard and evidence sufficiency.
The Supreme Court ultimately held that the trial court did not abuse its discretion and the evidence was sufficient; it clarified the applicable harmless-error standard and burden of production.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the mistrial properly denied for in-court identifications in jail clothing?	Ward	Ward	No abuse of discretion; no reversible error
What standard governs harmless error and prejudice for a mistrial in this context?	Ward	State	Established one standard (substantial rights) with constitution-based analysis when applicable
Was the evidence sufficient to convict Ward on the charged drug transactions?	Ward	Ward	Yes; sufficient evidence including direct and circumstantial proof

Chapman v. California, 386 U.S. 18 (U.S. Supreme Court, 1967) (federal harmless-error standard: beyond a reasonable doubt when the error implicates a constitutional right)
Kleypas, 272 Kan. 894, 40 P.3d 139 (2001) (harmful-error standard aligned with Chapman for constitutional errors)
Cosby, 285 Kan. 230, 169 P.3d 1128 (2007) (standard for harmless error considered equivalent to Chapman)
Dixon, 289 Kan. 46, 209 P.3d 675 (2009) (discussed us/ken standards and instructs on impact of prejudice and instructions)
Rinck, 256 Kan. 848, 888 P.2d 845 (1995) (standard: whether misconduct could have affected the result)
Leaper, 291 Kan. 89, 238 P.3d 266 (2010) (abuse-of-discretion review for mistrial decisions; two-step framework)
Alexander, 240 Kan. 273, 729 P.2d 1126 (1986) (discussion of harmless-error standard and trial-appearance considerations)
Hall, 220 Kan. 712, 556 P.2d 413 (1976) (appearance in prison clothing not per se reversible; prejudice required)
Fleury, 203 Kan. 888, 457 P.2d 44 (1969) (Kansas harmless-error doctrine linking to Chapman)
West, Nos. 99,063, 99,067, 2008 WL 4849472 (Kan. App. 2008) (unpublished; sufficiency of proof in proximity-to-school statutes)
Northcutt, 290 Kan. 224, 224 P.3d 564 (2010) (standard for sufficiency review: rational juror could find guilt beyond reasonable doubt)