Jeremias v. State

The Supreme Court affirmed Defendant’s convictions of one count each of conspiracy to commit robbery and burglary while in possession of a deadly weapon and two counts each of robbery with the use of a deadly weapon and murder with the use of a deadly weapon. On appeal, Defendant argued that the district court violated right to a public trial by closing the courtroom to members of the public during jury selection without making sufficient findings to warrant the closure. The Supreme Court held that, under Presley v. Georgia, 558 U.S. 209 (2010), this violation constituted structural error, but because Defendant did not preserve the error for appellate review, under Nevada law, Defendant must demonstrate plain error that affected his substantial rights. Following the United States Supreme Court’s guidance in Weaver v. Massachusetts, 582 U.S. __ (2017), the Supreme Court held that Defendant failed to satisfy plain error review. Further, Defendant was not entitled to relief on his other claims, and Defendant’s death sentences were supported by review of the record under Nev. Rev. Stat. 177.055(2). View "Jeremias v. State" on Justia Law