Ramos v. State

The Supreme Court affirmed Defendant's conviction for the sexual assault of a woman who was killed twelve years before Defendant was charged, holding that there was no statutory time limit in which the State was required to file the sexual assault charge, and the district court did not err in denying Defendant's motion to dismiss.

In 1998, two elderly victims were murdered in a retirement facility. In 2010, the State charged Defendant with murdering both victims and sexually assaulting the female victim. Defendant moved to dismiss the sexual assault charge, arguing that the State's prosecution was time-barred. The district court denied the motion, concluding that there was no limitations period for the offense under Nev. Rev. Stat. 171.083. Defendant was subsequently convicted of the murder of both victims and the sexual assault of the female victim. The Supreme Court affirmed, holding (1) the requirements of section 171.083 were satisfied, and therefore, there was no statutory time limit in which the State was required to file the sexual assault charge; and (2) the district court did not err in denying Defendant's motion to dismiss.