Beauclair v. StateAnnotate this Case
At issue was whether a criminal defendant’s claim of actual innocence may excuse procedural defaults that would otherwise bar litigation of motions filed under Kan. Stat. Ann. 60-1507.
The Supreme Court reversed the decision of the court of appeals affirming the district court’s summary denial of Defendant’s Kan. Stat. Ann. 60-1507 motion and remanded to the district court for an evidentiary hearing on his gateway claim of actual innocence. The motion underlying this appeal was untimely and successive, and to avoid the resulting procedural bars, Defendant argued manifest injustice based on his claim of actual innocence. The Supreme Court held that Defendant’s assertion of actual innocence entitled him to an evidentiary hearing to determine its credibility. Specifically, the Court held that an evidentiary hearing was required to determine whether Defendant’s assertion established manifest injustice or exceptional circumstances sufficient to require the district court to address the merits of his ineffective assistance of counsel claim.