The Kansas Supreme Court affirmed the first-degree murder conviction of Ricky L. Hollins on March 7, 2025, in a case that clarified important standards regarding jury instruction practices during criminal trials.
Hollins was convicted of first-degree premeditated murder following the death of S.D. on the night of October 21, 2020. According to court records, Hollins had arranged to meet the victim for a paid sexual encounter when an altercation occurred that resulted in S.D.'s death. While the court noted the facts of the case were gruesome, it emphasized that the specific details were not relevant to the legal issues raised in the appeal.
A jury in Sedgwick District Court convicted Hollins of first-degree premeditated murder but acquitted him of a misdemeanor charge of buying sexual relations. District Judge Eric Williams sentenced Hollins to a hard 50 life sentence, meaning he must serve 50 years before becoming eligible for parole.
Hollins appealed his conviction, raising three primary issues before the Kansas Supreme Court. The most significant challenge involved a statement made by the district court directing the jury to participate in discussion during deliberations. Hollins argued this instruction was legally erroneous and prejudiced his right to a fair trial.
The Kansas Supreme Court rejected this argument, establishing in its syllabus that "It is not legally erroneous to instruct a jury to engage in discussion during deliberations." This ruling provides clarity for trial courts across Kansas regarding acceptable jury instruction practices and reinforces the importance of jury deliberation as a collaborative process.
Hollins also renewed his objections to the premeditation instruction that the Kansas Supreme Court previously approved in *State v. Bernhardt*, 304 Kan. 460, 372 P.3d 1161 (2016). The *Bernhardt* case established standards for how courts should instruct juries on the element of premeditation in first-degree murder cases. Despite Hollins' continued challenge to this instruction, the court maintained its position that the *Bernhardt* standard remains appropriate.
The defendant's final argument centered on cumulative error, claiming that multiple alleged errors during his trial combined to deny him a fair trial. Under the cumulative error doctrine, even if individual errors might not warrant reversal on their own, multiple errors can collectively undermine the integrity of a trial. The Kansas Supreme Court found this argument unpersuasive and determined that Hollins received a fair trial.
The case was argued before the Kansas Supreme Court on October 29, 2024, with Justice Stegall delivering the court's opinion. Korey A. Kaul of the Kansas Appellate Defender Office represented Hollins, while Assistant District Attorney Matt J. Maloney argued for the state. District Attorney Marc Bennett and Attorney General Kris W. Kobach also appeared on the brief for the appellee.
The ruling in *State v. Hollins* carries implications beyond this specific case. The court's clarification that encouraging jury discussion during deliberations is legally sound provides guidance for trial judges who must balance ensuring proper jury procedures with avoiding instructional error that could lead to reversible error on appeal.
Jury deliberation instructions have long been a source of appellate litigation, as courts must walk a careful line between providing helpful guidance to jurors and avoiding comments that might improperly influence their decision-making process. The Kansas Supreme Court's affirmation that encouraging discussion is acceptable helps establish boundaries for permissible jury instructions.
The case also demonstrates the ongoing tension between defendants' rights to challenge established jury instruction precedents and the legal system's interest in maintaining consistent standards. Hollins' renewed challenge to the *Bernhardt* premeditation instruction reflects continuing debate about how courts should explain complex legal concepts to juries.
For practitioners in Kansas criminal law, the decision reinforces existing standards while providing additional clarity on jury instruction practices. The court's rejection of the cumulative error argument also suggests a relatively high threshold for overturning convictions based on multiple alleged trial errors.
The affirmation of Hollins' conviction means he will continue serving his hard 50 life sentence. The case represents another example of the Kansas Supreme Court's careful review of criminal convictions while maintaining established legal precedents that have guided jury instructions in serious felony cases.
This decision adds to the body of Kansas law governing jury instructions in capital and serious felony cases, providing trial courts with additional guidance on acceptable practices during the critical deliberation phase of criminal trials.