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Kahler v. Kansas

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Supreme Court of the United States
Kahler v. Kansas
Term: 2019
Important Dates
Argument: October 7, 2019
Decided: March 23, 2020
Outcome
Affirmed
Vote
6-3
Majority
Elena Kagan • John G. Roberts • Clarence Thomas • Samuel Alito • Neil Gorsuch • Brett Kavanaugh
Dissenting
Stephen Breyer • Ruth Bader Ginsburg • Sonia Sotomayor


Kahler v. Kansas is a case argued before the Supreme Court of the United States on October 7, 2019, during the court's October 2019-2020 term. The case came on a writ of certiorari to the Kansas Supreme Court.

The court affirmed the decision of the Kansas Supreme Court in a 6-3 ruling, holding that due process does not require Kansas to adopt an insanity test that is dependent on a defendant’s ability to recognize that their crime was morally wrong.[1] Click here for more information.

HIGHLIGHTS
  • The case: James Kahler was convicted of capital murder and sentenced to death. On appeal, Kahler argued the prosecution violated his right to a fair trial. The Kansas Supreme Court rejected Kahler's argument, affirming his conviction and sentence. Kahler appealed to the U.S. Supreme Court, arguing Kansas law violates his constitutional rights under the Eighth and 14th Amendments.
  • The issue: Do the Eighth and 14th Amendments permit a state to abolish the insanity defense?
  • The outcome: The court affirmed the decision of the Kansas Supreme Court in a 6-3 ruling, holding that due process does not require Kansas to adopt an insanity test that is dependent on a defendant’s ability to recognize that their crime was morally wrong.[1]


    • You can review the lower court's opinion here.

    Timeline

    The following timeline details key events in this case:

    • March 23, 2020: The U.S. Supreme Court affirmed the Kansas Supreme Court's ruling.
    • October 7, 2019: Oral argument
    • March 18, 2019: The U.S. Supreme Court agreed to hear the case.
    • September 28, 2018: James Mahler filed a petition with the U.S. Supreme Court.
    • February 9, 2018: The Kansas Supreme Court affirmed Kahler's conviction and sentence.

    Background

    In 2009, James Kahler shot and killed his wife, his two daughters, and his wife's grandmother, in Burlingame, Kansas. The State of Kansas charged Kahler with capital murder and aggravated burglary. During the trial, the defense presented testimony from Dr. Stephen Peterson, a forensic psychiatrist, who said Kahler was suffering from severe depression and did not have the capacity to control his behavior. The prosecution presented testimony from Dr. William Logan, also a forensic psychiatrist, who suggested Kahler was capable of forming the requisite intent to commit the crimes and premeditation.[2]

    The jury convicted Kahler of capital murder. He was sentenced to death.[2]

    On appeal, Kahler argued the prosecution violated his right to a fair trial. The Kansas Supreme Court rejected Kahler's argument, affirming his conviction and sentence.[2]

    Kahler appealed to the U.S. Supreme Court. In his petition for a writ of certiorari, Kahler argued that Kansas law "violates the Eighth Amendment’s prohibition of cruel and unusual punishments and the Fourteenth Amendment’s due process guarantee." According to the petition, the Kansas law in question adopted the standard that insanity or mental disease was irrelevant as a defense.[3]

    Questions presented

    The petitioner presented the following questions to the court:

    Questions presented:
    • Do the Eighth and Fourteenth Amendments permit a state to abolish the insanity defense?[4]

    Outcome

    In a 6-3 opinion, the court affirmed the Kansas Supreme Court's judgment. The court held that due process does not require Kansas to adopt an insanity test that depends on a defendant’s ability to recognize that their crime was morally wrong. Justice Elena Kagan delivered the opinion of the court.[1]

    Opinion

    In her opinion, Justice Elena Kagan wrote:[1]

    “ This case is about Kansas's treatment of a criminal defendant's insanity claim. In Kansas, a defendant can invoke mental illness to show that he lacked the requisite mens rea (intent) for a crime. He can also raise mental illness after conviction to justify either a reduced term of imprisonment or commitment to a mental health facility. But Kansas, unlike many States, will not wholly exonerate a defendant on the ground that his illness prevented him from recognizing his criminal act as morally wrong. The issue here is whether the Constitution's Due Process Clause forces Kansas to do so--otherwise said, whether that Clause compels the acquittal of any defendant who, because of mental illness, could not tell right from wrong when committing his crime. We hold that the Clause imposes no such requirement.[5] ”
    —Justice Kagan

    Dissenting opinion

    Justice Stephen Breyer filed a dissenting opinion, joined by Justices Ruth Bader Ginsburg and Sonia Sotomayor.[1]

    In his dissent, Justice Stephen Breyer wrote:[1]

    “ Like the Court, I believe that the Constitution gives the States broad leeway to define state crimes and criminal procedures, including leeway to provide different definitions and standards related to the defense of insanity. But here, Kansas has not simply redefined the insanity defense. Rather, it has eliminated the core of a defense that has existed for centuries: that the defendant, due to mental illness, lacked the mental capacity necessary for his conduct to be considered morally blameworthy. Seven hundred years of Anglo-American legal history, together with basic principles long inherent in the nature of the criminal law itself, convince me that Kansas' law "offends . . . principle[s] of justice so rooted in the traditions and conscience of our people as to be ranked as fundamental." Leland v. Oregon, 343 U. S. 790, 798 (1952) (quoting Snyder v. Massachusetts, 291 U. S. 97, 105 (1934)).[5] ”

    Text of the opinion

    Read the full opinion here.

    Audio

    Audio of oral argument:[6]



    Transcript

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 Supreme Court of the United States, Kahler v. Kansas, decided March 23, 2020
    2. ↑ 2.0 2.1 2.2 Kansas Supreme Court, State v. Kahler, decided February 9, 2018
    3. ↑ Supreme Court of the United States, "Petition for a writ of certiorari," September 28, 2018
    4. ↑ Supreme Court of the United States, "Questions presented: 18-6135 Kahler v. Kansas," accessed June 7, 2019
    5. ↑ 5.0 5.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ U.S. Supreme Court, "Oral Argument - Audio, Kahler v. Kansas," accessed October 21, 2019
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