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Quisano V. State, 132 Nev. Adv. Op. 9 (February 18, 2016), Michael Hua

Nevada Supreme Court Summaries

This court affirmed an appeal from a judgment of conviction, pursuant to an Alford plea, of voluntary manslaughter and child abuse, neglect, or endangerment with substantial bodily harm holding:

(1) Brady violations do not occur when the evidence in question is not favorable to the defendant;

(2) Prosecutors have a strict duty to disclose under their own open-file policy until sentencing proceedings; and,

(3) Media outlets require a written by the district court to electronically cover proceedings unless nonconstitutional or harmless error results in such coverage.

Taylor Vs. State, 132 Nev. Adv. Op. 27 (April. 21, 2016), Marta Kurshumova

Nevada Supreme Court Summaries

The Court determined that (1) access and usage of historical cell phone connection data without a warrant does not violate the Fourth Amendment if the “specific and articulable facts” standard is met, (2) the out-of-court and in-court identifications did not violate Taylor’s constitutional rights to due process of law, (3) the prosecutorial conduct during closing arguments did not violate Taylor’s Sixth Amendment right to a fair trial or Fifth Amendment right against self-incrimination, and (4) there was sufficient evidence at trial to support the jury's finding of guilt.

Newman V. State, 132 Nev. Adv. Op. 31 (April 28, 2016), Andrea Orwoll

Nevada Supreme Court Summaries

The Court reviewed two consolidated appeals involving sentencing concerns, which stemmed from a district court judgment revoking probation and a district court judgment of conviction pursuant to a guilty plea. The Court dismissed the appeal of the probation revocation because appellant did not present any cogent arguments on that issue and because she had already been released from the nine-month sentence, rendering the appeal moot. As to the judgment of conviction, the Court affirmed. The Court held that a court may consider a defendant’s status as a pregnant drug addict in sentencing, especially if the status brought up by the …