State v. Martin
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In Kansas, Miles Loren Martin was convicted of possession of methamphetamine and possession of a controlled substance without a drug-tax stamp. Martin appealed, arguing that these convictions violated constitutional protections against double jeopardy and a Kansas statute prohibiting multiple convictions for the same conduct.
The Kansas Supreme Court rejected Martin's argument. It held that possession of methamphetamine and failure to affix a drug-tax stamp were not the same offenses under the Kansas statute, because the former carried a higher penalty than the latter, and because the latter required an element (failure to affix the stamp) not required for the former. Consequently, the legislature had not prohibited multiple punishments for these offenses.
The court also held that Martin's convictions did not violate the Double Jeopardy Clauses of the U.S. and Kansas Constitutions. It reasoned that the legislature intended to impose multiple punishments for the offenses because they targeted different conduct (possession of an illegal narcotic versus failure to pay a drug tax) and carried different penalties.
On Martin's challenge to the search of his pill bottle, the court found that the search fell within the exception for a search incident to a lawful arrest. The court noted that the officer had a legitimate basis to arrest Martin before the search and that the arrest followed shortly after the search. The court also found that the search of the bottle did not exceed the permissible scope of a search incident to arrest.
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