Maestas v. State

Appellant Beau Maestas pleaded guilty to several charges, and a jury sentenced him to death for first-degree murder. Appellant subsequently sought a new penalty trial based on allegations of juror misconduct and bias, but the district court denied the motion. In these consolidated appeals, Appellant challenged the judgment of conviction and the order denying the motion for a new trial. The Supreme Court affirmed, holding principally that (1) Nev. Rev. Stat. 175.556 does not violate the Eighth Amendment because the relevant jurisprudence focuses on whether a capital sentencing scheme sufficiently channels the sentencer's discretion to impose a death sentence and does not afford the district court the discretion to impose a death sentence; and (2) the district court did not abuse its discretion by denying Appellant's motion for a new trial because no misconduct or bias was proved.