## Facts

- Three women in their early 20s (Joan Butler, Christine Rusch, and Theresa Brown) disappeared in Johnson County, Kansas in June 1989 and were never seen again; no remains were recovered.
- Richard Grissom, Jr., operated an apartment cleaning/painting business that had access to victims’ apartment complexes.
- Grissom rented a storage locker in Johnson County under an alias (“Randy Rodriguez”); handwriting evidence linked him to the rental paperwork.
- The State’s case was largely circumstantial and tied Grissom to the victims through access to their apartments, subsequent possession/use of their property (including credit cards and personal items), and his movements and conduct around the disappearances.
- A jury convicted Grissom of three counts of first-degree murder, aggravated kidnapping, multiple robberies, aggravated burglaries, and misdemeanor theft.
- Grissom appealed directly to the Kansas Supreme Court, raising numerous trial and legal challenges, including sufficiency, corpus delicti, jurisdiction, and charging theories of first-degree murder.

## Issues

1. Whether the State made an independent prima facie showing of the corpus delicti of each homicide sufficient to admit Grissom’s statements and support three first-degree murder convictions despite the absence of bodies.
2. Whether the circumstantial evidence, viewed under the appellate sufficiency standard, permitted a rational factfinder to find guilt beyond a reasonable doubt on the charged offenses.
3. Whether Kansas had territorial jurisdiction when the precise location of the killings was uncertain and aspects of the criminal conduct could have extended beyond Kansas.
4. Whether an information may charge first-degree murder in a single count on both premeditated and felony-murder theories, whether the State must elect between theories, and whether a general verdict is valid if jurors rely on different theories.

## Decision

- The Kansas Supreme Court affirmed all convictions.
- The court held the State presented sufficient independent, circumstantial evidence to make a prima facie showing of the corpus delicti for each homicide, allowing admission of Grissom’s statements.
- The court held the overall circumstantial evidence was sufficient for a rational jury to convict beyond a reasonable doubt.
- The court held Kansas had territorial jurisdiction because substantial and integral parts of an overall continuing criminal plan occurred in Kansas.
- The court held first-degree murder under Kansas law is a single offense that may be proved by alternative methods (premeditated murder or felony murder); the State need not elect between theories, and a general verdict is not defective merely because jurors may rely on different theories.

## Legal Principles

- Circumstantial evidence proves a fact in issue by proving other circumstances from which a reasonable inference of the fact in issue may be drawn.
- In homicide cases, corpus delicti requires proof that a person was killed and that another person caused the death; it may be shown by direct evidence, circumstantial evidence, or both.
- Corpus delicti must be established independently of the defendant’s admissions or confessions, but only a slight or prima facie showing is required to admit such statements; the trial court decides whether that threshold is met.
- Sufficiency of the evidence on appeal asks whether, viewing all evidence in the light most favorable to the prosecution, a rational factfinder could find guilt beyond a reasonable doubt.
- Kansas territorial jurisdiction exists when any element or the result occurs in Kansas, or when the defendant commits acts in Kansas that are a substantial and integral part of an overall continuing criminal plan executed in part within the state.
- Under K.S.A. 21-3401, first-degree murder is a single offense with alternative methods of proof; charging both premeditated and felony murder in one count is permissible, the State need not elect, and juror agreement on the specific theory is not required if each theory is legally supported.

## Conclusion

The Kansas Supreme Court upheld multiple “no-body” homicide convictions, concluding that extensive circumstantial evidence could establish the corpus delicti and support guilt beyond a reasonable doubt, that a prima facie corpus delicti showing suffices to admit a defendant’s statements, that Kansas had territorial jurisdiction based on in-state conduct integral to a continuing plan, and that first-degree murder may be charged and proved through alternative theories in a single count without prosecutorial election or theory-specific juror agreement.


State v. Grissom, 251 Kan. 851, 840 P.2d 1142 (Kan. 1992)