State v. Williams, 329 P.3d 420

Williams was convicted of felony murder, aggravated burglary, and aggravated assault after accompanying Kevin Brown, Quartez Brown, and Jaleesa Bonner to Bolden's apartment where Bolden was killed and Green was assaulted.
The State requested a no-sympathy jury instruction; the court gave it despite Williams's objection.
Williams requested modification to the aiding-and-abetting instruction to include language about mere association or presence; the court refused.
Williams argued trial counsel rendered ineffective assistance by pursuing a guilt-based strategy in closing.
The court addressed Williams's claims of cumulative error and ultimately found no reversible errors and affirmed the convictions.
Procedural posture involved direct appeal from Sedgwick County District Court; the panel reviewed multiple issues together under standard appellate review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the no-sympathy instruction was reversible error	Williams	State	Not reversible error under Baker/Ward standards.
Whether the aiding-and-abetting instruction should have been supplemented	Williams	State	Not reversible error; better practice to modify, but failure not reversible.
Whether Williams received ineffective assistance of counsel	Williams	State	Remand not required; direct-appeal review declined; cannot decide without 60-1507 record.
Whether cumulative error denied Williams a fair trial	Williams	State	No reversible cumulative error; total errors insufficient to overturn.

State v. Baker, 281 Kan. 997 (Kan. 2006) (no-sympathy instruction should be used only in unusual circumstances)
State v. Rhone, 219 Kan. 542 (Kan. 1976) (only case where sympathy instruction found sufficiently unusual)
State v. Edwards, 291 Kan. 532 (Kan. 2010) (refusal to give 'mere presence' language not reversible error)
State v. Hilt, 299 Kan. 176 (Kan. 2014) (modification of aiding-and-abetting instruction preferred but not reversible error)
State v. Jones, 298 Kan. 324 (Kan. 2013) (no-sympathy instruction not routinely provided)
State v. Ward, 292 Kan. 541 (Kan. 2011) (harmless-error standard for no-sympathy instruction)
State v. Plummer, 295 Kan. 156 (Kan. 2012) (procedure for reviewing instruction errors)
State v. Dull, 298 Kan. 832 (Kan. 2014) (ineffective-assistance generally not decided on direct appeal)
State v. Levy, 292 Kan. 379 (Kan. 2011) (Van Cleave remand guidance for IAC claims)
State v. Carter, 270 Kan. 426 (Kan. 2000) (per se ineffective-assistance concerns when counsel concedes guilt against client's wishes)