Sanchez (Jacob) v. State

sitting on a curb after he, Cassandra Niccoli, and Stephan Gale left a Reno club. He did not think much of it until a half a block later when he heard footsteps and a shout behind him and saw someone grab Niccoli's purse. Block identified Luis Sanchez as the person who hit him over the head when he went to Niccoli's aid. He observed the suspects flee in a white sedan. Niccoli identified Jose Cruz and Aurora Rodriguez as the people who approached her and tried to take her purse. A forensic investigator testified that she responded to the Reno Police Department to photograph four people who were possibly involved in the case. She identified these people as Sanchez, Luis Sanchez, Jose Cruz, and Aurora Rodriguez. We conclude that this independent evidence was sufficient to connect Sanchez to the commission of the offenses and thereby corroborate Luis Sanchez's and Aurora Rodriguez's testimony. Second, Sanchez contends that the district court erred by admitting autopsy photographs depicting the murder victim's heart and liver into evidence because they were very graphic and not needed to explain the cause of death. "The admissibility of gruesome photographs showing wounds on the victim's body lies within the sound discretion of the district court and, absent an abuse of that discretion, the decision will not be overturned." Flores v. State, 121 Nev. 706, 722, 120 P.3d 1170, 1180 (2005) (internal quotation marks omitted). The record reveals that the district court conducted a hearing outside the presence of the jury to determine the admissibility of the photographs. The district court viewed the photographs, heard testimony from the forensic pathologist, considered the parties' arguments, and found that the photographs would assist the jury in determining a fact in issue. We conclude from this record that the district court did not abuse its discretion. SUPREME COURT OF NEVADA 2 (0) 1947A 1,14, Third, Sanchez contends that the district court committed plain error by admitting evidence of unrelated crimes during the penalty phase of his trial. "The decision to admit particular evidence during the penalty phase is within the sound discretion of the district court and will not be disturbed absent an abuse of that discretion." McKenna v. State, 114 Nev. 1044, 1051, 968 P.2d 739, 744 (1998). "[E]vidence may be presented concerning aggravating and mitigating circumstances relative to the offense, defendant or victim and on any other matter which the court deems relevant to the sentence, whether or not the evidence is ordinarily admissible." NRS 175.552(3). "[E]vidence of unrelated offenses for which a defendant has not been convicted is admissible at a penalty phase unless it is dubious or tenuous or its probative value is substantially outweighed by the danger of unfair prejudice or the other concerns set forth in NRS 48.035." Mason v. State, 118 Nev. 554, 562, 51 P.3d 521, 526 (2002). We have reviewed the penalty hearing transcript and conclude that Sanchez has failed to demonstrate that the district court committed plain error in this regard. See Mclellan v. State, 124 Nev. 263, 267, 182 P.3d 106, 109 (2008) (discussing plain-error review). Having concluded that Sanchez is not entitled to relief, we ORDER the judgment of conviction AFFIRMED. Gibbons Lug .441/4--s Douglas Saitta SUPREME COURT OF NEVADA 3 (0) 1947A cc: Hon. Patrick Flanagan, District Judge Edward T. Reed Attorney General/Carson City Washoe County District Attorney Washoe District Court Clerk SUPREME COURT OF NEVADA 4 (0) 1947A affilila iThIMM 1111