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State v. Crawford

Supreme Court of Kansas
253 Kan. 629 (1993)


Facts

At the time of this case, § 21-3209 of the Kansas Statutes provided that a defendant was not guilty of a crime, other than murder or voluntary manslaughter, if he acted under compulsion or a reasonable belief that he or a member of his immediate family was threatened with imminent death or serious bodily harm. The statute further provided that this defense did not apply if the defendant’s willful or reckless conduct made it likely that he would be put under compulsion or threat. Crawford (defendant) was a drug addict who owed money to Bateman for cocaine purchased on credit. Bateman asked Crawford to commit robberies in order to pay the debt, and Bateman’s girlfriend gave Crawford a gun. While the three of them were parked outside a hospital, Bateman told Crawford to rob a woman entering the parking lot. The woman fled and gave Crawford her wedding rings, after which Crawford approached Monhollon, entered Monhollon’s car at gunpoint, robbed him and drove away with Monhollon at the wheel, leaving Bateman and his girlfriend behind. Crawford then robbed Monhollon’s house and two other homes, keeping Monhollon at gunpoint, and later forced Monohollon to withdraw cash from an ATM. Finally, Crawford put Monhollon in the trunk of the car and drove to a motel where he met Bateman, who was dissatisfied with the value of the stolen goods and told Crawford to commit another robbery. Monhollon eventually escaped from the trunk and contacted the police. Crawford was arrested and charged with multiple counts of aggravated robbery, aggravated battery, aggravated burglary, and kidnapping. At his trial, Crawford argued that Bateman had threatened to kill him and his son and that Bateman belonged to the Moorish Americans, a dangerous religious group. Crawford also introduced expert testimony that he suffered from drug dependency, depression, and a personality disorder that made him dependent and fearful of Bateman. The court instructed the jury on the defense of compulsion, quoting from § 21-3209 and adding that the mere threat of future injury did not constitute an imminent threat sufficient to constitute a defense. Crawford was convicted on all counts and appealed to the Supreme Court of Kansas.

Rule of Law

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Issue

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Holding and Reasoning (Allegrucci, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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