May 15th. The Kansas Supreme Court has issued its opinion in State v. Ransom (No. 99,281) a felony-murder appeal. In a unanimous opinion, written by Justice Carol Beier, the Court upheld Kendrall Ransom’s conviction for the felony-murder of Spain Bey. Note: As a result of former Chief Justice Kay McFarland’s retirement, Judge Melissa Standridge of the Court of Appeals was appointed to hear the case.
Kendrall Ransom was an 18 year old gang member (though jurors were not told that) in March of 2006 when he and a group of friends and associates took part in a pair of poorly planned drug house robberies in Wichita. They first attempted to rob one Donta McDonald, who Ransom shot and killed. In this case Ransom is not appealing that crime (which was covered here [the felony-murder conviction of one of his accomplices]) but the conviction arising out of that evening’s second robbery. Having come away from the McDonald killing with no drugs or money Ransom and some others raided a house on North Lorraine. Ransom knocked on the door holding a shotgun and said he was there to buy drugs. The occupants saw the gun and slammed the door and everyone involved ran away at some point – except for one Spain Bey who was found in the house shot to death.
Later that night Ransom and the others were pleased by the evening news which they watched at an associate’s house which showed the police were looking for a different type of vehicle to the one they had been driving. They were less pleased a couple of days later when an anonymous tip led police to that house, several guns and ultimately the various participants in the crimes. Ransom was charged with Felony Murder for the death of Bey. [At trial a forensics expert testified that the weapons recovered were not used to kill Bey – who exactly shot Bey remains a mystery, but is of course not necessarily relevant for a Felony Murder conviction]. A jury convicted him.
This case is Ransom’s direct appeal and as a result he made a series of claims for why his conviction should be reversed. The opinion almost devotes more time to describing the procedural background than to dismissing each of the issues which Ransom raised. None of them appears to have stood much chance of success.
- The Court held that interruptions in Ransom’s interview schedule and an (unsupported) claim that he had been drinking and taking Ecstasy did not require that he be re-Mirandized. His confession to participating in the crimes was therefore admissible.
- The Court held that testimony about the way Ransom and the others celebrated the news report about the type of car that was being looked for by police was neither a violation of the Sixth Amendment right to confront, nor inadmissible hearsay.
- The Court rejected an argument that the jury should have received an instruction which would have required to find some causational link between Ransom’s actions and Bey’s death over and above the death being as a result of the attempted robbery.
- The Court rejected an argument that Ransom should have received a mistrial because one of the police officers referred to “gang officers” in testimony when the trial judge had barred admission of evidence concerning Ransom’s gang ties.
- The Court rejected an argument that the State should not have been able to alter the charge after both sides had presented their evidence. [It should be noted that the change in the charge was to include an additional component of the same subsection of the Felony Murder statute, namely to include the flight from the scene as something linked to Bey’s death, and the trial had already covered evidence about the events in the amended charge].
- The Court rejected an argument that the evidence of Felony Murder was insufficient, since a rational fact-finder could have found Ransom guilty based on the evidence presented.
Therefore, Ransom’s conviction was affirmed.