State v. Williams, 299 Kan. 509

Corky A. Williams was convicted of premeditated first-degree murder, conspiracy to commit first-degree murder, and criminal possession of a firearm in a joint trial arising from Dyer's death.
Armstrong cooperated with the State before trial, later recanted, and testified inconsistently across trials; his testimony was admitted in various forms at Williams’ trial.
Multiple versions of events were presented at trial, including Armstrong, Phillips, Kettler, Williams, and Johnson, with conflicting accounts of planning, firing, and who possessed the gun.
Evidence showed a past confrontation where Dyer robbed Williams, fueling alleged motives for retaliation; gun possession and concealment were central to the State’s theory.
The jury convicted Williams after weighing direct and circumstantial evidence, including eyewitness accounts, forensic findings, and Armstrong’s sworn statements.
On appeal, Williams challenged sufficiency of evidence, jury instructions, evidentiary rulings, Batson claims, prosecutorial conduct, and alleged trial deficiencies, with the court ultimately affirming.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for premeditated murder	Williams asserts lack of proof of premeditation.	State argues Armstrong's statements and circumstantial factors prove premeditation.	Evidence supported premeditation beyond reasonable doubt.
Conspiracy to commit first-degree murder	Williams challenges existence of an agreement to kill Dyer.	State contends Armstrong’s statements and conduct show a tacit agreement among all four.	Sufficient evidence supported an agreement to kill.
Aiding and abetting versus mere association	Prosecution failed to prove Williams aided the murder beyond mere presence or association.	State showed Williams helped facilitate the murder by transporting others and hiding a gun.	Aiding and abetting proven; statutory charging issues do not render the theory defective.
Batson challenge to peremptory strikes	State struck African-American jurors with discriminatory intent.	Strikes were race-neutral and based on non-discriminatory factors; no purposeful discrimination.	Trial court did not abuse discretion; no Batson violation established.
Prosecutorial misconduct in closing arguments	Prosecutor misstated premeditation law and invoked street justice; affected fairness.	Misstatements were not reversible errors given context and strong evidence; harmless beyond a reasonable doubt.	Misconduct found but not reversible; error deemed harmless.

Batson v. Kentucky, 476 U.S. 79 (1986) (establishes prohibition on race-based peremptory challenges)
State v. Holmes, 278 Kan. 603, 102 P.3d 406 (2004) (premeditation inference standards; caution against instant-premeditation language)
State v. Cosby, 293 Kan. 121, 262 P.3d 285 (2011) (premeditation and instruction guidance)
State v. Hall, 292 Kan. 841, 257 P.3d 272 (2011) (prosecutor closing arguments and error preservation guidance)
State v. Betancourt, 299 Kan. 131, 322 P.3d 353 (2014) (aiding and abetting statute does not create alternative means; liability theory)
State v. Wright, 290 Kan. 194, 223 P.3d 1159 (2010) (alternative means analysis in sufficiency review)
State v. Gant, 288 Kan. 76, 201 P.3d 673 (2009) (discussion of aiding and abetting intent in circumstantial contexts)