State v. Woods
301 Kan. 852
| Kan. | 2015Background
- Woods shot and killed his wife in daylight on a residential street; multiple witnesses saw him shoot her and then fire a close-range fatal shot when she was on the ground. He was arrested at the scene and made incriminating statements, including in a videotaped police interview.
- A pretrial COMCARE competency evaluation (requested over Woods' objections) concluded Woods showed no psychotic symptoms, had some erratic behavior but was competent to understand proceedings and assist counsel.
- At a competency hearing Woods repeatedly interrupted and objected to discussion of mental illness; the district court admitted the COMCARE report and found Woods competent to stand trial.
- Woods moved to suppress his recorded police interview arguing his mental condition and low intellect prevented a knowing, voluntary Miranda waiver; the court denied suppression and admitted the videotaped confession.
- Jury convicted Woods of premeditated first-degree murder and criminal possession of a firearm; the court denied a voluntary manslaughter instruction and later ordered Woods to register under KORA; Woods appealed multiple rulings.
Issues
| Issue | Plaintiff's Argument (Woods) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Adequacy of competency hearing | Hearing was insufficient; court should have more thoroughly questioned intellectual disability and medication refusal | Statutory process under K.S.A. 22-3302 complied with due process; COMCARE evaluation and hearing provided opportunity to show incompetence | No procedural due process violation; statutory process adequate |
| Competence finding | COMCARE and court erred; prior diagnoses (schizophrenia, low IQ) plus behavior show incompetence | COMCARE found no psychosis; behavior consistent with efforts to derail process; presumption of competence and preponderance standard not met by Woods | No abuse of discretion; court properly found Woods competent |
| Sua sponte re-evaluation during trial | Later erratic conduct (yawning, laughing, tissue in ears) should have triggered new competency evaluation | Incidents were isolated, consistent with prior evaluation view, and defense counsel did not press the issue; no new bona fide doubt | No abuse of discretion in declining another evaluation |
| Voluntariness / Miranda waiver (taped interview) | Intellectual disability/untreated mental illness prevented a knowing, voluntary waiver; belief he needed to speak to learn about wife/kids coerced waiver | Video and testimony show Woods understood rights, signed waiver, answered coherently; no coercion or inducement | Waiver voluntary under totality; confession admissible |
| Limitation on voir dire | Court improperly barred asking jurors about personal history of mental illness (relevance to bias) | Mental illness not in evidence and defense was not asserting insanity defense; question irrelevant and invasive | Court within discretion to limit voir dire as irrelevant |
| Sufficiency of evidence for premeditation | Shooting was quick and provoked by argument; insufficient to prove premeditation | Multiple shots including a final close-range shot after victim felled supports premeditation factors | Evidence sufficient; jury could find premeditation beyond a reasonable doubt |
| Lesser included instruction (voluntary manslaughter) | Evidence supported heat-of-passion instruction due to argument, marital breakup, provocation | Evidence was only verbal confrontation; no objective provocation adequate to cause ordinary person to kill | No factual basis for voluntary manslaughter instruction; district court correct |
| KORA registration / Apprendi challenge | Registration order and signed notice implicate judicial factfinding about deadly weapon and Woods' capacity to sign | First-degree murder conviction alone (K.S.A. 22-4906(a)(1)(F)) mandates registration; form merely notifies duty to register | Registration proper based on conviction; signing notice not void on record presented |
Key Cases Cited
- Medina v. California, 505 U.S. 437 (U.S. 1992) (procedural test: process must afford reasonable opportunity to show incompetence)
- Dusky v. United States, 362 U.S. 402 (U.S. 1960) (competency standard: factual and rational understanding and ability to consult with counsel)
- Barnes v. State, 263 Kan. 249 (Kan. 1997) (Kansas competency statute provides adequate procedure to protect right not to be tried while incompetent)
- McGregor v. Gibson, 248 F.3d 946 (10th Cir. 2001) (distinction between procedural and substantive competency claims)
- Drope v. Missouri, 420 U.S. 162 (U.S. 1975) (trial court should consider defense counsel's doubts about competence)
- Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (rule on judicial factfinding that increases punishment beyond statutory maximum)
- Colorado v. Connelly, 479 U.S. 157 (U.S. 1986) (confession involuntariness requires coercive police activity; mental condition alone insufficient)