Hernandez v. State

CourtCourt of Appeals of Kansas
DecidedSeptember 5, 2025
Docket127163
StatusUnpublished

This text of Hernandez v. State (Hernandez v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hernandez v. State, (kanctapp 2025).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 127,163

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

JEREMY L. HERNANDEZ, Appellant,

v.

STATE OF KANSAS, Appellee.

MEMORANDUM OPINION

Appeal from Montgomery District Court; DANIEL D. CREITZ, judge. Submitted without oral argument. Opinion filed September 5, 2025. Affirmed.

Kristen B. Patty, of Wichita, for appellant.

Steven J. Obermeier, assistant solicitor general, and Kris W. Kobach, attorney general, for appellee.

Before WARNER, C.J., CLINE and COBLE, JJ.

PER CURIAM: Jeremy L. Hernandez appeals the Montgomery County District Court's order denying his motion for habeas corpus relief under K.S.A. 60-1507. The district court ruled that Hernandez' motion was untimely, notwithstanding the deficient representation by postconviction retained counsel, and that Hernandez had not established a manifest injustice warranting tolling the filing limitation for eight years. On a thorough examination of the record, we affirm the district court's ruling.

1 FACTUAL AND PROCEDURAL BACKGROUND

In 2004, a jury convicted Hernandez of committing the first-degree murder of Tina Davidson on November 26, 1995.

Direct Criminal Proceedings

Initially, law enforcement had few leads in the murder investigation. Eight years after the murder, Hernandez was arrested for a different crime, and he was required to submit a DNA sample. His DNA was compared to DNA retained in a database and matched to DNA extracted from blood collected at the murder scene that did not belong to Davidson. State v. Hernandez, 284 Kan. 74, 76, 159 P.3d 950 (2007).

During his subsequent police interview, Hernandez initially told the police that he did not know Davidson and denied ever visiting her home. But, at trial, Hernandez' account shifted, and he told the jury that he gave Davidson a ride home after finding her stranded on the side of the road. Davidson allegedly invited Hernandez into her home for a drink. While Hernandez and Davidson were talking in her kitchen, another man entered the house, became angry, and aggressively confronted Hernandez, cutting his hand with a knife. When Davidson tried to calm the man, he turned on Davidson, and Hernandez left the house. Hernandez learned from friends about two weeks later that Davidson had been murdered. Hernandez did not tell the police about the man who allegedly confronted him at any point before his trial. 284 Kan. at 77.

Still, Hernandez' account of the murder was substantially undermined by his wife's testimony. She reported that, before they were married, Hernandez told her that he had been involved in a murder in Independence. He told her that he had "'driven a friend to someone's house, and he [the defendant] had sat and watched while [his friend] killed [a woman].'" 284 Kan. at 78. Hernandez' wife further testified that he told her that nothing

2 came of the murder investigation because the police lacked evidence. 284 Kan. 78. Later, in his own trial testimony, Hernandez acknowledged the conversation but said that he believed his wife had not been listening to him. 284 Kan. at 78.

Though presented with a lesser included offense of second-degree murder, the jury convicted Hernandez of premeditated first-degree murder. On January 4, 2005, the court sentenced Hernandez to serve life in prison without the possibility of parole for 40 years (hard 40). Hernandez appealed his conviction to the Kansas Supreme Court. Although the court concluded that Hernandez had established some errors in his trial, the court affirmed the conviction, finding the evidence of Hernandez' guilt to be overwhelming. 284 Kan. at 96-98.

"The State's case against the defendant did not turn on the fact that the defendant remained silent after he was charged with the crime. Instead, it was based on a number of pieces of evidence, including the fact that his DNA matched that of the trail of blood drops found surrounding Davidson's body and leading from her residence, that he provided inconsistent statements to the police officers, and that he had acknowledged his participation in Davidson's murder to his wife, then fiancée, Jessica Hernandez. Jessica testified that the defendant had asked her at one time whether she 'knew what a lot of blood smelled like.' She stated that he then told her that he had been involved in a murder of a woman in Independence, had driven to the woman's house, and watched as his friend 'cut up' the victim. She also explained that the defendant had told her that the case had remained unclosed because the police 'didn't have evidence and it just couldn't be solved.' This testimony, provided by the defendant's wife, is in sharp contrast to the innocent story provided by the defendant. Moreover, as the previous discussion demonstrates, the prosecutor's comments concerning the fact that the defendant did not come to the police with his story in the 8 years between Davidson's murder and the time he was charged were admissible to impeach the credibility of the defendant's testimony under Jenkins [v. Anderson, 447 U.S. 231, 100 S. Ct. 2124, 65 L. Ed. 2d 86 (1980)]." Hernandez, 284 Kan. at 95-96.

3 Hernandez applied for writ of certiorari to the United States Supreme Court, but his application was denied on November 13, 2007. Hernandez v. Kansas, 552 U.S. 1025, 128 S. Ct. 620, 169 L. Ed. 2d 399 (2007).

Postconviction Procedural History

On August 13, 2018, Hernandez filed a motion under K.S.A. 60-1507, accompanied by an affidavit explaining the filing delay and a memorandum in support of his motion. The district court appointed Hernandez an attorney, Daniel Reynolds, who filed a motion to extend the filing limitation deadline, based on the alleged deficient representation of Hernandez' retained postconviction attorney, Bradley P. Sylvester. The district court held a limited evidentiary hearing on the quality of Sylvester's representation and the timeliness of Hernandez' motion. At the hearing, the parties presented relatively uncontroverted evidence about Sylvester's representation and Hernandez' conduct following the termination of that representation.

After the Kansas Supreme Court affirmed his conviction, Hernandez and his family decided to pursue a habeas corpus action under K.S.A. 60-1507 and retained Sylvester for that purpose. Sylvester initially accepted a check for $5,000 as a retainer. While Sylvester did not recall when Hernandez' family first approached him, he testified that the family members contacted him in 2008, and the retention check was dated February 22, 2008.

Sylvester investigated Hernandez' case by speaking with the family, communicating with Hernandez by phone, reviewing the trial record, and speaking with Hernandez' trial attorney. But Sylvester did not file a habeas corpus motion on Hernandez' behalf.

4 In conducting his own legal research, Hernandez discovered that a habeas corpus motion under K.S.A. 60-1507 was subject to a one-year limitation. Hernandez contacted his father about the limitation, and in turn, his father contacted Sylvester.

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Related

Jenkins v. Anderson
447 U.S. 231 (Supreme Court, 1980)
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466 U.S. 668 (Supreme Court, 1984)
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