State v. Phinney

CourtCourt of Appeals of Kansas
DecidedNovember 7, 2025
Docket126714
StatusUnpublished

This text of State v. Phinney (State v. Phinney) 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
State v. Phinney, (kanctapp 2025).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 126,714

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

RIGO OLIVER PHINNEY, Appellant.

MEMORANDUM OPINION

Appeal from Shawnee District Court; MABAN WRIGHT, judge. Submitted without oral argument. Opinion filed November 7, 2025. Affirmed.

Ryan J. Eddinger, of Kansas Appellate Defender Office, for appellant.

Carolyn A. Smith, assistant deputy district attorney, Michael F. Kagay, district attorney, and Kris W. Kobach, attorney general, for appellee.

Before WARNER, C.J., ATCHESON and ISHERWOOD, JJ.

PER CURIAM: Rigo Oliver Phinney stands convicted of two counts of involuntary manslaughter and one count of reckless driving as a result of conduct that took the lives of two motorcycle riders. He brings this appeal contending that the State failed to offer sufficient evidence of wantonness that he alleges was required to establish the mens rea for each charged offense. The legal authority that Phinney relies on as the foundation for his claim that involuntary manslaughter requires proof of wanton conduct is outdated, however, and does not provide an avenue of relief. Rather, under the current involuntary manslaughter statute, recklessness is sufficient to secure a conviction. Following a

1 thorough review of the evidence in a light most favorable to the State, we are satisfied there was sufficient evidence offered at trial to enable a reasonable jury to conclude that Phinney was guilty beyond a reasonable doubt of the charged offenses. Accordingly, his convictions are affirmed.

FACTUAL AND PROCEDURAL BACKGROUND

Anthony Vardys, along with his son, Dillon, formed the Midwest Brotherhood Motorcycle Club (MWB), a family-oriented organization that enabled individuals to share their hobby with and enjoy the camaraderie of like-minded riders. Motorcycle riding was a big part of the members' lives, so they rode together as often as their schedules allowed and organized fundraisers for charitable causes in their community.

On the evening of March 20, 2021, approximately 10 MWB members attended an open house sponsored by another area riding club. The MWB group left the event around 10 p.m. to return to Topeka via Highway 24, adopting their standard zipper formation within a single lane, wherein the riders alternated from left to right but not directly adjacent to one another. The posted speed limit was 55 miles per hour, and the group generally maintained a speed between 52 and 60 miles per hour. As the riders made their way into town, they crested the top of a hill and began their descent into a flat stretch of highway that was flanked on both sides by an access road and businesses.

Around this same time, Phinney was helping his roommate, Randy Clelland, resolve a problem with his work truck. Clelland's large white utility truck broke down near the intersection of Highway 24 and Meriden Road, and Phinney agreed to help tow it with his black passenger pickup truck. Clelland attached a roughly 30-foot-long standard metal chain between the two trucks but they neglected to affix any flags to the chain to ensure that connection was visible. The plan was for Phinney to perform the towing

2 function with his own truck while Clelland assisted by steering the incapacitated truck. Both trucks had their headlights on, but the drivers did not activate their hazard lights.

Around this time, Phinney and Clelland's other roommate, Melissa Britton, arrived at the scene. Britton was riding as a passenger in a car driven by Jeramie Lamm when she recognized her roommates' trucks and told Lamm to stop so they could help. Lamm turned on his hazard lights and took up a position behind the two trucks. The vehicles made their way onto the access road north of Highway 24 and headed west. They eventually turned onto the eastbound lanes of Highway 24 and proceeded until they reached the intersection of Highway 24 and Meriden Road, where they pulled into the median and prepared to turn left onto Meriden Road.

After oncoming traffic passed, Phinney started to turn but quickly realized that the chain had fallen off so he backed up and Clelland reattached the chain. After Clelland performed that task, Phinney scanned the westbound highway lanes for oncoming traffic and noticed the glow emanating from the MWB riders' LED headlights as they cleared a hill. He started across the intersection, and when he looked again, the motorcycles were closing in on the bottom of the hill. Phinney observed the motorcycles approaching in the westbound lanes but, more concerned with getting the trucks across Highway 24 and onto northbound Meriden Road than honoring the yield sign which established that the motorcycles had the right-of-way, Phinney continued to cross the intersection.

Despite their short window of time, the pair of trucks was moving slowly because Clelland had to maintain pressure on the truck's brakes to ensure the chain remained taut so it would not fall off again. As the motorcycles drew closer, their headlights gradually illuminated the pair of trucks in the median and when the group was roughly a few hundred yards away, they saw Phinney start to enter the highway. Uncomfortable with how close they were to the intersection when Phinney moved forward, the bikers let off their throttles to slow down. It was not until they were approximately 50 yards from the

3 intersection that the bikers realized the trucks were connected. Attempting to prevent a collision, they hit their brakes, signaled to each other to slow down, and took evasive maneuvers.

Phinney yelled to himself, "Come on, come on, come on" as the motorcycles bore down on the trucks. He made it across the highway lanes onto Meriden Road, but the bed of Clelland's truck was still in the right lane of the highway when the bikers reached the intersection. Britton, watching from the car in the median, realized that a collision was inevitable.

The bikers on the left side of the staggered formation managed to skirt around the back of the second truck and those in the rear of the formation were able to stop before they reached the second truck. Unfortunately, Anthony Vardys and his wife, Tamara, who were riding the first motorcycle on the right side of the formation collided with the second truck with a significant degree of force and both were thrown from the bike. Tamara's body violently struck the side of the truck, and she died at the scene. Anthony was projected over it and landed on the pavement. He died at the hospital later that evening.

Phinney was charged with two counts of involuntary manslaughter, eight counts of endangerment, two counts of improper towing, and one count each of reckless driving, driving while suspended, driving without insurance, and failure to yield. Following a jury trial, the district court entered a judgment of acquittal for one count of improper towing and he was found guilty on all remaining counts, with the exception of driving without insurance. Phinney was sentenced to serve a total term of 44 months' imprisonment.

Phinney now brings his case before this court to determine whether the State presented sufficient evidence at trial to prove beyond a reasonable doubt that he possessed the requisite mental states for involuntary manslaughter and reckless driving.

4 LEGAL ANALYSIS

Whether Phinney's knowledge of the risks associated with the circumstances satisfies the requisite mental state for convictions of involuntary manslaughter and reckless driving

Phinney contends that his convictions for involuntary manslaughter and reckless driving must be reversed.

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State v. Phinney, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-phinney-kanctapp-2025.