Authors

Keaunui Harris

Document Type

Case Summary

Publication Date

9-10-2023

Case Synopsis

On appeal from a judgment of conviction, the appellant must have made timely objections to preserve the record in order to facilitate appellate review. Additionally, there are three types of juror bias that may lead to the removal of a juror: actual bias, implied bias, and inferable bias. If a juror’s statements establish implied or inferable bias, the juror must be removed regardless of whether that juror subsequently expresses impartiality. By contrast, if a juror’s statements suggest actual bias, the juror can still serve on the jury panel if the district court, after canvassing the juror, determines that they will be impartial despite the bias.

Finally, under the Nevada Pattern Jury Instructions: Criminal, the correct wording for an instruction for larceny from the person deems property as taken “from the person of another” if it is in some way actually upon or attached to the person or carried or held in actual physical possession.

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