State v. Irons

Facts

Brandon Irons (Defendant) was sent to the Wichita Community Residential Center (CRC), a work-release facility for inmates. One day, Defendant signed out to go to work but failed to return the next morning. Defendant was eventually charged with aggravated escape from custody. Prior to trial, the State made a motion requesting that the court exclude any evidence pertaining to Defendant’s motives for escaping. During the motion hearing, Defendant testified that the other inmates had become angry about an interview he had given about the CRC. After Defendant signed out to go to work, he was chased by two inmates and ran into a store for safety. The inmates told Defendant that they were going to kill him when he returned. While at work, Defendant called the CRC and spoke to Ryan, the assistant administrator, who agreed to call Defendant later that evening but never did. Defendant called again a number of times but could not reach Ryan. Instead of returning to the CRC, Defendant went to Texas and stayed there until he was arrested five months later. Defendant argued that his testimony supported a defense of compulsion under Kansas law, which provided that a person was not guilty of a crime based on conduct performed under the compulsion or threat of imminent death or great bodily harm. The trial court granted the State’s motion and excluded Defendant’s testimony, concluding that the threats were not sufficiently imminent to allow for a compulsion defense. Defendant was convicted of aggravated escape. Defendant appealed the conviction.