Supreme Court of Kansas

State v. Coble

January 15, 2021479 P.3d 201

Summary

The court reversed Coble's aggravated-arson conviction because three identical counts, indistinguishable instructions, and generic verdict forms left it impossible to determine which alleged incident supported the guilty verdict. The resulting uncertainty prevented meaningful appellate review of the evidence and implicated Coble's due process rights. The court also rejected the conclusion that Coble invited the error because the proposed supplemental instruction would not have resolved the ambiguity.