On June 17, 2022, the Kansas Supreme Court held that circumstantial evidence is sufficient to convict someone of a violation of the Kansas Offender Registration Act (KORA), K.S.A. 22-4902 et seq. In State v. Darnell Huey (June 17, 2022), Huey had recently been released from prison and was ordered to register as a violent offender in the county he would reside, work, or attend school. Huey registered in Shawnee County and signed paperwork acknowledging that he would notify authorities if his residence changed. He then failed to renew his registration, which led to him being charged. At trial, only circumstantial evidence was admitted to prove that Huey still resided in Shawnee County and he was found guilty. On appeal, Huey argued that the jury should not have assumed that he still lived in Shawnee County at the time of the violation without some direct evidence. The Court rejected his argument, holding the jury’s verdict was based on a reasonable inference.
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