State of Kansas, Appellee v. Jerold Michael Dunn, Appellant

Summary

The court held that Kansas charging documents do not confer subject matter jurisdiction; jurisdiction derives from the Kansas Constitution, while charging-document defects are analyzed as statutory or constitutional errors. It overruled prior rules requiring every statutory element in the charging document and requiring special appellate treatment based on when the challenge was raised, but affirmed Dunn's convictions because the forgery-count defect was harmless and the stalking evidence was sufficient. Johnson, J., dissenting in part, agreed that the forgery count failed to charge a Kansas crime but rejected the majority's authority to preserve the conviction through harmless-error analysis.