State v. Crawford

Supreme Court of Kansas
861 P.2d 791 (1993)

ELI5:

Rule of Law:

The criminal defense of compulsion requires a threat of imminent, present, and impending death or great bodily harm, with no reasonable opportunity for the defendant to escape. A threat of future injury is insufficient to establish this defense.

Facts:

Ace Crawford owed money to his cocaine supplier, Larry Bateman.
Bateman provided Crawford with a gun and instructed him to commit robberies in Topeka to pay off the debt.
Crawford robbed and physically assaulted Nancy Jo Overholt in a hospital parking lot.
Immediately after, Crawford kidnapped Mark Monhollon at gunpoint from the same parking lot and forced him to drive to Monhollon's duplex.
At the duplex, Crawford robbed Monhollon, then used him to gain entry into the neighboring apartment of Bernice Looka, whom he also robbed.
Crawford then forced Monhollon to drive to the home of Nancy Kinney, where he robbed and assaulted her.
Crawford forced Monhollon to withdraw money from an ATM before locking him in the trunk of the car and driving to a hotel in another city.
Crawford later claimed he committed these crimes under duress, testifying that Bateman had threatened to harm his son, who lived in St. Louis, and that Bateman was connected to a violent group.

Procedural Posture:

Ace Crawford was charged with multiple felonies in a Kansas district court.
A jury found Crawford guilty of seven counts of aggravated robbery, two counts of aggravated battery, two counts of kidnapping, and four counts of aggravated burglary.
The district court sentenced Crawford to a controlling term of 60 years to life imprisonment.
Crawford filed a direct appeal of his convictions and sentence to the Supreme Court of Kansas.

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Issue:

Does a jury instruction stating that the defense of compulsion requires a threat to be 'present, imminent and impending' and that a 'threat of future injury is not enough' constitute a clearly erroneous statement of Kansas law?

Opinions:

Majority - Allegrucci, J.

No. The jury instruction on compulsion was a correct statement of established Kansas law. The defense of compulsion under K.S.A. 21-3209 requires a threat of the 'imminent' infliction of death or great bodily harm. Citing precedent from State v. Milum, State v. Harrison, and State v. Myers, the court reaffirmed that the threat must be present, impending, and continuous, and there must be no reasonable opportunity for the defendant to escape. The court held that threats of future injury, such as Bateman's alleged threats against Crawford's son in another city, are insufficient as a matter of law. The court rejected Crawford's attempt to analogize his situation to the battered person syndrome, stating that the weakness in his defense was the indefiniteness of the threat. Finally, the court noted that K.S.A. 21-3209(2) makes the defense unavailable to one who, like Crawford, willfully places himself in a situation where compulsion is probable.

Analysis:

This decision reinforces the narrow and strict interpretation of the compulsion defense in Kansas, refusing to expand the definition of 'imminent' threat. The court explicitly rejects incorporating subjective psychological states or long-term coercive relationships, such as a 'battered person syndrome' analysis, into the compulsion framework, distinguishing it from the defense of self-defense. The ruling solidifies the objective standard that the threat must be immediate and the defendant must have had no reasonable opportunity to escape or seek help from authorities. This precedent makes it significantly more difficult for defendants involved in criminal enterprises, such as drug trafficking, to later claim they were compelled to commit crimes by their associates.

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