Why a Topeka man wrongfully convicted of murder isn't eligible for compensation

The Kansas Supreme Court rejected civil compensation for William Spangler, who shot and killed Faustino Martinez outside his Topeka apartment in March 2013.

The Shawnee County convicted Spangler of second-degree murder for the shooting, which was later overturned. Spangler then received the lesser charge of involuntary manslaughter. With time served, Spangler had already been in prison four and a half years longer than he would have if convicted of involuntary manslaughter at the outset.

Spangler introduced a civil proceeding for wrongful conviction after he was sentenced to a lesser charge and released to seek compensation for the four additional years he was imprisoned. But the Kansas Supreme Court found him ineligible because of his own conduct to "cause or bring about the conviction.”

The shooting of Faustino Martinez

Spangler and Martinez had a verbal confrontation outside the Capital Suites apartment complex where Spangler lived. After the argument, Spangler went to his apartment and retrieved a loaded AR-15 rifle and returned to the parking lot.

Spangler said he tried to scare off Martinez with the weapon, which didn’t work, and he fired what he called a “warning shot.” When Martinez didn’t flee, Spangler said he fired another shot at Martinez’s leg but hit him in the stomach.

Shawnee County District Court sentenced him to more than 15 years in prison, which the Kansas Court of Appeals affirmed. Later, Spangler filed a motion for relief arguing that his attorney failed to give sufficient counsel in the case, particularly for not investigating a robbery and assault Spangler suffered weeks before that might have affected his decision-making during the shooting.

At retrial in 2022, Spangler was convicted of involuntary manslaughter. He then was released as he had already served four years more time than he would have if he was originally convicted of involuntary manslaughter.

Wrongful convictions and monetary relief

Kansans who are wrongfully convicted are eligible for up to $65,000 for every year served in a wrongful conviction. However, the claimant can’t collect that money if their conduct led to the conviction.

Because Spangler didn’t dispute that he shot and killed Martinez, the court found that he wasn’t eligible for monetary relief. The court said the legislative intent of Kansas’s wrongful conviction law is to provide relief for people who are found to have not done the offense, rather than a court’s interpretation of it.

“What distinguishes the offenses is the degree of recklessness,” the Kansas Supreme Court said. “In other words, the underlying behavior or conduct is the same for second-degree murder and involuntary manslaughter. Only the mental state differs.”

This article originally appeared on Topeka Capital-Journal: Kansas Supreme Court says Topeka man isn't eligible for compensation