Sunday, November 17, 2013

State v. Crawford case brief

State v. Crawford case brief summary
253 Kan. 629 (1993)


CASE SYNOPSIS
Defendant sought review of a decision of the Shawnee District Court (Kansas), which convicted him of aggravated robbery, aggravated battery, kidnapping, and aggravated burglary. Defendant was sentenced to a controlling term of 60 years to life in prison.

CASE FACTS
At trial, a psychiatrist had testified that defendant suffered from chronic drug dependence and use, chronic depression, battered person syndrome and depression arising from it, and an extremely dependent personality disorder. He was of the opinion that defendant committed the crimes because defendant feared his dealer. Defendant's dealer told him to commit crimes to pay for his drug debt.

DISCUSSION
  • On appeal, defendant contended that the trial court's instruction on his compulsion to commit the crimes was erroneous under Kan. Stat. Ann. § 21-3209(1), which provided that a person was not guilty of a crime by reason of conduct which he performed under the compulsion or threat of the imminent infliction of death or great bodily harm, if he reasonably believed that death or great bodily harm would be inflicted upon him. 
  • However, under § 21-3209(2), § 21-3209(1) was not applicable to one who willfully placed himself in a situation in which it was probable that he would be subjected to compulsion or threat. 
  • The court held that § 21-3209(1) was not applicable to defendant because the required element of an imminent threat was missing because defendant had the opportunity to escape.

CONCLUSION
The court affirmed the decision of the trial court, which convicted defendant.

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