Justia Nevada Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's conviction of sex trafficking of a child under eighteen years of age, first-degree kidnapping, living from the earnings of a prostitute, and child abuse, neglect, or endangerment, holding that the trial court's Faretta canvass was in appropriate in this case.Defendant, who represented himself at trial, was found guilty of sex trafficking of a child under eighteen years of age, first-degree kidnapping, living from the earnings of a prostitute, and child abuse, neglect, or endangerment. The Supreme Court reversed Defendant's conviction on the basis that the waiver of his right to counsel was invalid, holding (1) the trial court's determination that Defendant validly waived his right to counsel was unreasonable in light of the inadequate inquiry into Defendant's understanding of the sentences he faced if convicted; and (2) the trial court should refrain from disparaging Defendant's choice to waive counsel. View "Miles v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and related charges, holding that there was no reversible error in jury selection or closing arguments.During his trial, Defendant stipulated to a sentence of life without the possibility of parole if he was found guilty and to waive his right to appeal issues "stemming from the guilt phase of the trial." The jury found Defendant guilty, and the court sentenced Defendant to life without the possibility of parole. On appeal, Defendant raised errors relating to the denial of his pretrial motion to suppress evidence, jury selection, closing arguments, jury deliberations, and sentencing. The Supreme Court affirmed, holding (1) Defendant did not waive any error that occurred during closing arguments, sentencing or jury selection; and (2) Defendant waived his other alleged errors. View "Burns v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing Appellant's 42 U.S.C. 1983 civil rights claims and state law tort claims, holding that the district court erred by requiring Appellant to administratively exhaust all potential remedies.Appellant brought this complaint alleging that Georgina Stuart, who was employed by the Clark County Department of Family Services (DFS), and two police officers forced him to sign a temporary guardianship over his two minor children to the children's maternal aunt. DFS subsequently made a findings of maltreatment against Appellant, which he administratively appealed. The district court dismissed Appellant's request for punitive damages as not available and dismissed Appellant's section 1983 and state law tort claims for failure to exhaust his administrative remedies. The Supreme Court reversed in part, holding (1) Appellant was not required to administratively exhaust all potential remedies in his DFS case before bringing his section 1983 and tort claims; and (2) the district court erred by finding that Appellant's section 1983 claim was solely a procedural due process claim subject to the exhaustion doctrine. View "Eggleston v. Stuart" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant's complaint alleging discrimination based on age and sex, holding that Appellant's complaint was untimely filed.Following Respondent's termination of Appellant, Appellant sent a letter of inquiry to the Equal Employment Opportunity Commission and filed a charge of discrimination. After the limitation period for Appellant's potential claims against Respondent expired the Legislature amended Nev. Rev. Stat. 613.430, providing employees an additional ninety days to file a claim after receiving a letter giving them the right to sue. Appellant subsequently filed this complaint, alleging discrimination. The district court granted Respondent's motion to dismiss, finding that Appellant's claims expired under the former version of Nev. Rev. Stat. 613.430 and that the Legislature's amendments to that statute did not revive the claims. The Supreme Court affirmed, holding (1) the district court properly determined that the amendment did not revive Appellant's untimely claims; and (2) Appellant failed to establish the requirements for equitable tolling. View "Salloum v. Boyd Gaming Corp." on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence recovered during a warrantless inventory search of his vehicle, holding that the plain-view exception to the warrant requirement of the United States and Nevada Constitutions applied in this case.Following a lawful stop and arrest of Defendant, a police officer performed a warrantless inventory search of Defendant's vehicle that produced no formal inventory. The officer, however, observed contraband during the search, leading to criminal charged being filed against Defendant. Defendant filed a motion to suppress, alleging that the evidence recovered from the vehicle was the product and fruit of an illegal search. The district court denied the motion, concluding that the evidence was validly discovered under the plain-view exception to the warrant requirement. The Supreme Court affirmed, holding that the plain-view exception to the warrant requirement applied because the officer was legally present in the vehicle at the time he observed the contraband. View "Jim v. State" on Justia Law

The Supreme Court vacated the judgment of the district court denying Defendant's motion to withdraw his guilty plea, denying Defendant's subsequent motion to dismiss the charges against him, and entering a judgment of conviction based on Defendant's guilty plea, holding that the district court erred in denying Defendant's motion to withdraw his guilty plea.Defendant entered into a guilty plea agreement based on charges of robbery and ownership or possession of a firearm by a prohibited person and then suffered a mental breakdown. Defendant sought to withdraw his guilty plea when he regained competency, alleging a violation of his right to a speedy trial and that his trial counsel provided ineffective assistance. The district court denied Defendant's motions and convicted him. The Supreme Court vacated the judgment below, holding that withdrawal was just and fair, and therefore, the district court erred in denying Defendant's motion to withdraw his guilty plea. View "Sunseri v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of two counts each of sexual assault of a minor under fourteen years of age and lewdness with a child under the age of fourteen, holding that the cumulative effect of serious errors violated Defendant's due process right to a fair trial.During trial, the State presented no physical evidence to prove that Defendant committed the offenses. Still, the jury found Defendant guilty of all counts, and he was sentenced to serve an aggregate prison term totaling thirty-five years to life. The Supreme Court reversed the convictions, holding (1) a comment made by the district court undermining the presumption of innocence constituted judicial misconduct; (2) a juror committed misconduct by goggling the term "common sense," and prejudice resulted; (3) certain statements made by the prosecutor during the State's closing argument constituted misconduct; and (4) cumulative error warranted reversal. View "Gunera-Pastrana v. State" on Justia Law

The Supreme Court vacated Defendant's judgment of conviction and remanded the case, holding that the district court denied Defendant due process by failing to conduct a competency hearing when reasonable doubt arose about Defendant's competency.Pursuant to a jury verdict, Defendant was convicted of murder with the use of a deadly weapon. On appeal, Defendant argued that he was denied due process under the United States and Nevada Constitutions when the district court failed to order a competency hearing. The Supreme Court vacated Defendant's judgment of conviction, holding that a trial court must order a hearing sua sponte to determine whether a defendant is competent when their is a reasonable doubt about his competency, and to fulfill its duty to order a competency hearing a trial court must follow Nevada's statutory competency procedures. View "Goad v. State" on Justia Law

The Supreme Court reversed the judgment of the district court in favor of Plaintiffs on their Title IX and 42 U.S.C. 1983 claims against a school district for student-on-student harassment and remanded for further findings on the Title IX claim, holding that the district court erred by concluding that Plaintiffs established each of the elements on the section 1983 claim.Plaintiffs, two students and their parents, brought these claims for harassment after two sixth-graders targeted the students with sexual slurs, other insults, and physical assaults. After a bench trial, the district court found for Plaintiffs on both their Title IX and section 1983 claims. The Supreme Court reversed, holding (1) Title IX's protections against sex-based discrimination extend to prohibit discrimination against homosexual and transgender individuals and discrimination based on perceived sexual orientation; (2) the district court properly found that the harassment in this case was "on the basis of sex for purposes of Title IX; (3) remand was required for further findings on the Title IX claim; and (4) the district court erred in relying solely on the violation of state law to satisfy "deliberate indifference," an essential element of both the Title IX and section 1983 claims. View "Clark County School District v. Bryan" on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant's petition for a writ of habeas corpus, holding that the plain language of Nev. Rev. Stat. 34.810(1)(a) excludes claims of ineffective assistance that do not allege a deficiency affecting the validity of the guilty plea, as well as claims alleging deficiencies that occur only after the entry of the guilty plea.Appellant was convicted of three counts of aggravated stalking. Appellant later filed a postconviction habeas petition, raising several claims of ineffective assistance of trial counsel and appellate counsel. The district court dismissed nearly all of the claims, finding that they fell outside the scope of postconviction habeas claims allowed by section 34.810(1)(a). The Supreme Court affirmed, holding that all of Appellant's ineffective assistance claims were outside the scope of cognizable claims under section 34.810(1)(a) and thus were properly dismissed. View "Gonzales v. State" on Justia Law