The recent opinion of the Supreme Court of Kansas in State v. Trickle, 2026 WL 2672272 (Kan. 2026) starts with this provocative paragraph:

Was Kristen Trickle murdered in her sleep by her husband, Colby Trickle? Or did she commit suicide while her husband lay next to her unaware? A jury believed the former, convicting Trickle of murder in the first degree and interference with law enforcement. This is Trickle’s direct appeal.

Kristen died on Halloween morning, 2019, and, as law enforcement worked the case, its

investigation uncovered that on October 21, 2019, Trickle’s phone was used to conduct a Google search for, “[W]hat is a spouse SGLI amount[?]” SGLI stands for service member’s group life insurance. Trickle also received information on SGLI via text message from a military superior on October 20, 2019. Trickle claimed he did not conduct the search, and suggested Kristen had. But investigators found video footage from Walmart showing that Kristen was at work at the time of the Google search, and she was not using Trickle’s phone. Trickle ultimately received $100,140.75 from the SGLI payout in February 2020. He also received a payout from Kristen’s life insurance policy with her employment at Walmart in January 2020.

At Colby’s murder trial, the prosecution presented evidence of how he used some of the life insurance proceeds. As the Supreme Court of Kansas explained:

The district court allowed the State to admit into evidence that Trickle used the life insurance proceeds he received from his wife’s death to purchase a life-sized sex doll. The defense did not object to listing where Trickle made purchases with the life insurance proceeds, it only objected to what Trickle purchased at “True Touch Dolls.” At oral argument, the State conceded that admitting this evidence was error, but argued the error was harmless. Because the State concedes error, we assume error without deciding the issue. Because, as illustrated below, the State concedes other errors, we reserve our evaluation of harmlessness for cumulative error.

The Supreme Court of Kansas ultimately ruled that there was enough evidence of Colby’s guilt to render this error harmless. In doing so, however, the court did not cite to the recent ruling of the U.S. Supreme Court in Andrew v. White, which recognized a Constitutional right to exclude evidence. As I wrote in A Constitutional Right to Exclude Evidence,

In Andrew, a wife was accused of murdering her husband.464 At trial, the prosecution presented prejudicial evidence such as evidence connected to the wife taking a trip to Mexico with her new boyfriend after her husband died. For instance, the prosecutor brandished a thong she took on the trip “and insinuat[ed] that no true grieving widow would pack such underwear and leave for Mexico with her boyfriend.”

In Andrew, the U.S. Supreme Court recognized that defendants can claim that evidence such as the thong evidence violated the Due Process Clause by rendering their trials fundamentally unfair. I’m not sure the sex doll purchase in Trickle satisfies that standard, but I certainly think it comes close.