State v. WARRIOR
277 P.3d 1111
| Kan. | 2012Background
- Warrior was convicted of premeditated first-degree murder and conspiracy to commit first-degree murder for Jeremy Warrior's killing.
- The State presented motive from marital discord, extramarital affair with Rodgers, and life-insurance benefits.
- Moore, a codefendant who pleaded guilty, testified with credibility attack and impeachment potential.
- Warrior gave multiple hospital statements to police without Miranda warnings; interrogations occurred during hospitalization.
- Rodgers and Moore were involved in planning and carrying out the murder, including rental of a SUV used in the attack.
- There were additional trial issues raised on appeal including evidentiary rulings and jury instructions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| suppression of hospital-interview statements | Warrior asserts custodial interrogation occurred | State contends interviews were noncustodial | Not custodial; statements admissible |
| Brady violations and materiality | State failed to disclose Moore's juvenile burglary adjudication | No Brady violation; evidence not material | No reversible Brady violation; not material to outcome |
| Hearsay about marital trouble | Hearsay impacted motive evidence | Evidence admissible as non-hearsay or harmless | Harmless error; cumulative impact not prejudicial |
| Deadlocked jury instruction | Instruction erroneous following Salts | Erroneous but not clearly erroneous in case context | Instruction not clearly erroneous; no reversal warranted |
| Cumulative error analysis | Cumulative errors deprived fairness | Errors were not collectively prejudicial | Cumulative errors not sufficient to overturn verdict |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (miranda warnings required for custodial interrogation)
- Bagley v. United States, 473 U.S. 667 (U.S. 1985) (materiality standard for Brady violations refined)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (reasonable probability standard for materiality)
- United States v. Turner, 674 F.3d 420 (5th Cir. 2012) (Brady materiality reviewed de novo with fact-findings deferentially reviewed)