State v. Brown

Susan Brown (defendant) arranged for her employee, Teresa Lawrence, to obtain the baby of a former employee, Samantha Pruitt, under an agreement in which Pruitt would give up her baby in exchange for a car, a cell phone, and $800, with Brown set to receive half that amount, $400, for arranging the deal. Pruitt handed over the baby to Lawrence, but the payment to Brown had not yet been made when Brown was convicted under a Kansas statute making it a felony to knowingly and intentionally receive or accept clearly excessive fees in connection with an adoption. Brown appealed, arguing that because she hadn't actually been paid the $400, she had not yet "received or accepted" it.