Lamb v. State, 251 P.3d 700

Susan Bivans was shot eight times outside her daughter's grade school; Lamb was the primary suspect with a history of obsession toward Susan.
Lamb's journals, writings, and surveillance of Susan were introduced at trial to show motive and identity; the State argued Lamb scripted the murder from a novel and other materials.
Lamb had prior writings and behavior suggesting fixation, including stalking, gatekeeping disputes over parental guardianship, and bitterness over disinheritance.
Police encountered Lamb shortly after the murder; during a pre-warrant, in-apartment encounter, Lamb stated, 'I have a revolver, but I found it,' which was admitted under public safety urgency.
Lamb challenged numerous trial rulings including Miranda applicability, impeachment, jury procedures, evidentiary rulings, jury note handling, and the ex parte jury-bailiff communication.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the unwarned statement was admissible under the public safety exception	Lamb; unwarned statement arose from custodial interrogation for weapons.	Lamb; public safety exception should apply only to immediate officer/public danger and here was not protective in nature.	Statement admissible under public safety exception
Whether cross-examination comments violated the Fifth Amendment	Lamb contends impeachment with prior statements violated Doyle v. Ohio and Miranda rules.	State argues impeachment allowed where statements not involuntary and not silence after warnings.	No improper comment; impeachment proper
Whether Batson challenge to juror removal was proper	Lamb asserts purposeful discrimination against African-American juror.	State provides race-neutral rationale (late arrival) with no pretext.	Batson challenge denied
Whether the bailiff's ex parte jury communication was harmless error	Bailiff communicated to jury about judge's absence; potential prejudice to verdict.	Communication was innocuous and did not affect deliberations.	No prejudicial impact; harmless error

In re Quarles, 467 U.S. 649 (1984) (public safety exception to Miranda permits unwarned questions about weapon location)
Miranda v. Arizona, 384 U.S. 436 (1966) (establishes Miranda warnings; public safety exception creates narrow departure)
Byford v. State, 116 Nev. 215, 994 P.2d 700 (2000) (instructional error and strategies in Byford framework)
Meyer v. State, 119 Nev. 554, 80 P.3d 447 (2003) (limits on automatic prejudice from extrinsic juror influence)
Remmer v. United States, 347 U.S. 227 (1954) (presumed prejudice standard for jury exposure to outside influence (limited here))