This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- In May 2020, the Defendant approached the Victim and her boyfriend while they were panhandling. The Victim and her boyfriend were homeless, and the Victim was addicted to Fentanyl. The Defendant offered to provide money for food and a hotel room. After retrieving their belongings from their broken-down car, the Defendant rented a hotel room for them. While the Victim's boyfriend was away buying groceries, the Defendant sexually assaulted the Victim in the hotel room. The Victim complied with the Defendant's demands out of fear (paras 3-5).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Appellant: Argued that the district court erred by admitting expert testimony as lay testimony, accommodations for a hearing-impaired juror and a discussion of the accommodations without the Defendant's presence resulted in reversible structural error, the false imprisonment conviction was incidental to the CSP conviction violating double jeopardy rights, and the district court erred by denying the motion for a new trial (para 1).
- Appellee: [Not applicable or not found]
Legal Issues
- Whether the district court erred by admitting expert testimony as lay testimony.
- Whether accommodations for a hearing-impaired juror and a discussion of the accommodations without the Defendant's presence resulted in reversible structural error.
- Whether the Defendant’s false imprisonment conviction was incidental to the CSP conviction, thereby violating his right to be free from double jeopardy.
- Whether the district court erred by denying the Defendant’s motion for a new trial (para 1).
Disposition
- The Court of Appeals affirmed the district court's decisions on all counts (para 1).
Reasons
-
The Court of Appeals held that the district court did not abuse its discretion by allowing the investigating detective's testimony as it was based on personal experience and not specialized knowledge, thus not constituting expert testimony (paras 7-14). The Court also found that the Defendant's presence at the status hearing regarding the hearing-impaired juror was not required as it was not a critical stage of the proceedings, and the Defendant invited the error he complained of by approving the juror's accommodations (paras 15-31). Furthermore, the Court determined that the false imprisonment conviction was not incidental to the CSP conviction and did not violate the Defendant's double jeopardy rights because the conduct was not unitary (paras 32-45). Lastly, the Court affirmed the denial of the Defendant's motion for a new trial on jurisdictional grounds, as the motion did not present newly discovered evidence and was not filed within the required timeframe (paras 46-50).
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