Narrative Opinion Summary
This case involves an appeal by a defendant convicted of multiple offenses, including domestic battery by strangulation, domestic battery causing substantial bodily harm, and possession of controlled substances with intent to sell. The Supreme Court of Nevada affirmed the domestic battery convictions, finding sufficient evidence to support the elements of strangulation and substantial bodily harm based on the victim's testimony and medical records. However, the court reversed the conviction for simple possession, ruling it a lesser-included offense of possession for sale, thus violating the Double Jeopardy Clause. The defendant was also adjudicated as a habitual criminal, a decision upheld by the court due to his multiple prior felony convictions. The court found no error in the procedural aspects of the habitual criminal adjudication, emphasizing that such status does not require an arraignment. Ultimately, the conviction for felony possession of a controlled substance was reversed, while the rest of the convictions, including the habitual criminal adjudication, were affirmed, resulting in significant sentences for the defendant.
Legal Issues Addressed
Definition and Proof of Strangulation under NRS 200.485(2)subscribe to see similar legal issues
Application: LaChance's conviction for domestic battery by strangulation was upheld based on evidence that he applied pressure to the victim's neck, impairing her breathing.
Reasoning: Evidence supported the conclusion that LaChance strangled Lane, as he applied pressure to her chest and neck, impairing her breathing and vision.
Double Jeopardy Clause and Lesser-Included Offensessubscribe to see similar legal issues
Application: The conviction for simple possession was reversed because it is a lesser-included offense of possession for sale, violating the Double Jeopardy Clause.
Reasoning: The Supreme Court of Nevada affirmed part of the conviction but reversed the conviction for simple possession, determining it is a lesser-included offense of possession for sale, thus violating the Double Jeopardy Clause.
Habitual Criminal Adjudication under NRS 207.010subscribe to see similar legal issues
Application: LaChance's adjudication as a habitual criminal was upheld due to his five prior felony convictions, which the court deemed sufficient without requiring an arraignment.
Reasoning: LaChance has five prior felony convictions, detailing specific offenses from 2001 to 2012, which confirms he has at least three distinct prior felonies relevant to habitual criminal status.
Procedural Requirements for Habitual Criminal Statussubscribe to see similar legal issues
Application: The court found no plain error in the notice procedure for habitual criminal status, as LaChance received adequate notice and the status is not a criminal charge.
Reasoning: The law allows for habitual criminal allegations to be added at various stages before sentencing, and since this status determination does not require jury consideration, no preliminary hearing or arraignment is necessary.
Substantial Bodily Harm under NRS 0.060subscribe to see similar legal issues
Application: The court affirmed that the victim's prolonged pain and serious injuries qualified as substantial bodily harm, supporting the conviction.
Reasoning: Evidence showed Lane experienced prolonged pain, with hospital treatment for severe injuries, immobility for several days, and lasting effects such as permanent shin splints and hearing loss, thus supporting the finding of substantial bodily harm.