Supreme Court of Kansas
Danny E. Beauclair, Appellant v. State of Kansas, Appellee.
June 22, 2018419 P.3d 1180
Summary
The court held that a colorable actual-innocence claim may serve as a gateway to overcome the time and successive-motion bars applicable to a postconviction motion. Because Beauclair presented recantations and an explanation for an allegedly false confession that could satisfy the applicable standard, the court required an evidentiary hearing to assess credibility and determine whether the claim establishes manifest injustice and exceptional circumstances. The court reversed and remanded for that hearing, with consideration of the underlying ineffective-assistance claim required only if the gateway claim is found colorable.