State v. Thille

CourtSupreme Court of Kansas
DecidedJune 13, 2025
Docket124495
StatusPublished

This text of State v. Thille (State v. Thille) is published on Counsel Stack Legal Research, covering Supreme Court 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. Thille, (kan 2025).

Opinion

IN THE SUPREME COURT OF THE STATE OF KANSAS

No. 124,495

STATE OF KANSAS, Appellee,

v.

MIKA LEE THILLE, Appellant.

SYLLABUS BY THE COURT

1. An imperfect self-defense instruction requires some evidence of a subjective belief that lethal force was necessary.

2. A voluntary manslaughter instruction under K.S.A. 21-5404(a)(1) for a killing done upon a "sudden quarrel or in the heat of passion" requires some objective evidence of sufficient provocation.

3. Whether sufficient provocation exists requires an objective determination of whether a reasonable person would lose self-control under the facts presented such that the person acts from extreme emotion rather than reason, regardless of the subjective belief of the defendant.

Review of the judgment of the Court of Appeals in an unpublished opinion filed August 25, 2023. Appeal from Saline District Court; RENE S. YOUNG, judge. Oral argument held September 10, 2024. Opinion filed June 13, 2025. Judgment of the Court of Appeals affirming the district court is affirmed. Judgment of the district court is affirmed.

1 Ryan J. Eddinger, of Kansas Appellate Defender Office, argued the cause and was on the brief for appellant.

Natalie Chalmers, assistant solicitor general, argued the cause, and Kris W. Kobach, attorney general, was with her on the brief for appellee.

The opinion of the court was delivered by

STEGALL, J.: Mika Lee Thille was convicted of reckless second-degree murder. Thille challenges his conviction on appeal and we affirm.

When Thille learned that his brother Max was at Justin Willingham's house, he left in the middle of the night with three companions—Valerie Vogel, Kayla Sitton, and Shannon Bryant—to go to the house. Max was using heroin at Willingham's house, and the group believed Max had taken Vogel's handbags from her hotel room a few hours earlier. In addition to being Thille's brother, Max had fathered children with Vogel. On arrival, Vogel led the group to the door and Willingham answered their knocking. Vogel yelled at Willingham, who was in the doorway, that she knew Max was inside and that he needed to return her bags. From there, witness testimony diverges.

According to Thille, he pushed past Vogel and demanded that Willingham get Max and return Vogel's belongings. Willingham reached for a gun at his hip, so Thille pushed Willingham and struck him in the face. A struggle ensued and Willingham's gun went off. Thille fell backwards and ultimately ran back out the front door. Vogel claimed that she remained outside while the rest of the group went into the house. She heard a scuffle and two gunshots before seeking refuge at a friend's house.

Sitton claimed she entered the home after Thille and Willingham engaged in a fistfight. She heard a gun go off, and then witnessed Thille draw a gun and fire multiple 2 shots at Willingham. Sitton fled and asked a neighbor to call 911 after she saw Thille drive away. For his part, Max claimed that Willingham drew a gun from his waistband and fired two shots into the ground. Max hit the ground for cover, and two more shots were fired, one of which killed Willingham.

Winnie Hogan, an occupant of the house, claimed that Willingham answered the door, two shots were immediately fired, and Willingham fell to the ground. Hogan claimed he stayed by Willingham's side until Willingham passed away and that there were two bullet holes in Willingham's chest. Other occupants of the house did not witness the shooting, only the aftermath. Justin Willingham died at approximately 3:41 a.m. from a gunshot wound to the chest. Thille turned himself over to law enforcement later that day and was taken into custody.

The State charged Thille with first-degree premeditated and felony murder, attempted first-degree murder, aggravated burglary, and attempted aggravated robbery. The district court also gave lesser included instructions for intentional and reckless second-degree murder. The jury convicted Thille of reckless second-degree murder and acquitted him of all other charges.

Thille raised challenges to the jury instructions before the Court of Appeals. He argued that the district court erred in denying his request for a lesser included offense instruction of voluntary manslaughter under both sudden quarrel and imperfect self- defense theories. Thille also argued, for the first time on appeal, that the jury should have received an involuntary manslaughter instruction as well.

The panel held that a voluntary manslaughter instruction was not factually appropriate under either theory. It further held that though an involuntary manslaughter instruction was factually appropriate, the district court's failure to give that instruction

3 was harmless. State v. Thille, No. 124,495, 2023 WL 5498984, at *10 (Kan. App. 2023) (unpublished opinion). We granted Thille's petition for review of these instructional issues, as well as the State's conditional cross-petition for review regarding the panel's conclusion that an involuntary manslaughter instruction was factually appropriate.

DISCUSSION

Appellate courts follow a multi-step process when analyzing jury instruction challenges: (1) determine whether the issue is preserved for appeal; (2) examine whether the instruction was factually and legally appropriate; and, if the court finds error, (3) conduct a reversibility inquiry. State v. Gentry, 310 Kan. 715, 720, 449 P.3d 429 (2019).

At the second step, we apply an unlimited standard of review of the entire record. In determining whether an instruction was factually appropriate, courts must determine whether there was sufficient evidence, viewed in the light most favorable to the defendant or the requesting party, that would have supported the instruction. State v. Holley, 313 Kan. 249, 254-55, 485 P.3d 614 (2021), on reh'g 315 Kan. 512, 509 P.3d 542 (2022). At the final step, if the issue was preserved for appeal and we find the district court erred, we apply either a constitutional or statutory harmless error test. Thille does not argue that a constitutional right was violated and advocates for the statutory test. Under the statutory test, a court assesses whether there is no reasonable probability any error affected the trial's outcome in light of the entire record. 313 Kan. at 256-57.

Voluntary Manslaughter

Thille argues the district court committed reversible error by refusing to instruct the jury on voluntary manslaughter under either his sudden quarrel or imperfect self-

4 defense theories. The State concedes that Thille preserved this argument for review, so any error discovered by the court must have had no reasonable probability in affecting the trial's outcome for the conviction to survive review. 313 Kan. at 256-57.

Under K.S.A. 22-3414(3), "[i]n cases where there is some evidence which would reasonably justify a conviction of some lesser included crime . . . the judge shall instruct the jury as to the crime charged and any such lesser included crime." Thus, a lesser included crime is generally legally appropriate. Gentry, 310 Kan. at 721.

Here, voluntary manslaughter is a lesser included offense of first-degree premeditated murder—which Thille was charged with—and thus the voluntary manslaughter instruction was legally appropriate. 310 Kan. at 721 ("Under this hierarchy, second-degree murder, voluntary manslaughter, and involuntary manslaughter are lesser included offenses of first-degree premeditated murder.").

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State v. Thille, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-thille-kan-2025.