The Court affirmed Lyons v. State, which gives the courts discretion to reject a defendant’s request for self-representation if the request is untimely. Further, the Court affirmed the Mendoza v. State test, which allows a single incident to sustain convictions for both robbery and kidnapping if any movement or restraint creates a risk to the victim substantially exceeding what is necessarily present in the crime of robbery. Finally, the Court held that the State must satisfy NRS § 193.165 to sustain deadly weapon charges.
Ristani, Xheni, "Guerrina v. State, 134 Nev. Adv. Op. 45 (June 7, 2018)" (2018). Nevada Supreme Court Summaries. 1168.