State v. Garcia-Martinez
Annotate this Case
The case revolves around Jose Garcia-Martinez, who was convicted for first-degree felony murder, aggravated kidnapping, aggravated battery, and battery. The incident occurred on July 1, 2020, when Garcia-Martinez and others attacked Roy Hayden, suspecting him to be a law enforcement officer. The group beat Hayden, confined him in a bathroom, and later moved him to the trunk of a car. Hayden's decomposed body was found days later in the abandoned car.
The case was initially tried in Sedgwick District Court, where Garcia-Martinez was found guilty. He appealed his convictions, arguing that the State presented alternative means of committing aggravated kidnapping and that the evidence was insufficient to support a finding of guilt on each of the alternative means. He also argued that the district court erred in refusing to give a unanimity instruction because the jury heard evidence of multiple acts that could have supported his aggravated kidnapping conviction.
The Supreme Court of the State of Kansas affirmed the lower court's decision. The court held that the phrase "taking or confining" in K.S.A. 21-5408(a) does not present alternative means of committing kidnapping and aggravated kidnapping; rather, it presents options within a means merely describing the factual circumstances that may prove the material element of holding the victim to accomplish one of the four alternative means of committing kidnapping set forth in the statute. The court also found that a unanimity instruction was not required because the evidence established a single continuous incident of aggravated kidnapping, not multiple acts.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.