Richards v. State, 249 P.3d 303

Richards was convicted in Alaska of third-degree assault and fourth-degree criminal mischief.
On Oct. 12, 2008, Richards and his wife fought after a night of heavy drinking; he allegedly attacked her, threw belongings outside, and then threw a splitting maul at her car, smashing the windshield.
Lorinda Richards fled in her car; a 911 call documented her distress and claims that Richards threw the maul through the windshield and tried to kill her.
Police later interviewed Richards; he claimed he was so drunk he had no memory of the events.
The jury heard conflicting exculpatory testimony from Richards and his son, but the court reviewed the evidence in the light most favorable to upholding the verdict.
Judge Collins sentenced Richards to 12 months to serve for the felony and 6 months to serve for the misdemeanor, with the two sentences concurrent and suspended time consecutive, yielding a 12-month active term and 18 months suspended.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the evidence sufficient to support the convictions?	Richards contends the evidence fails to prove guilt beyond a reasonable doubt.	State contends the record supports the jury's verdicts.	Yes; the evidence was sufficient to uphold the convictions.
May the court review the composite sentence for excessiveness given multiple offenses?	Richards argues the composite sentence is excessive and merits review.	State argues the trial court’s composite sentence is within range and jurisdiction for review is limited.	No; the court lacks jurisdiction to review the felony portion and declines to review the misdemeanor portion, referring the matter to the Alaska Supreme Court for discretionary review.

Rantala v. State, 216 P.3d 550 (Alaska App.2009) (standard for sufficiency of the evidence)
Robertson v. Riplett, 194 P.3d 382 (Alaska 2008) (subject-matter jurisdiction may be raised sua sponte)
O'Link v. O'Link, 632 P.2d 225 (Alaska 1981) (jurisdictional rules and standards)
Waters v. State, 483 P.2d 199 (Alaska 1971) (Chaney sentencing framework)
Custer v. State, 88 P.3d 545 (Alaska App.2004) (judicial review of totality in multiple offenses)
Jones v. State, 765 P.2d 107 (Alaska App.1988) (multif offense sentencing review principles)
Comegys v. State, 747 P.2d 554 (Alaska App.1987) (composite sentence analysis standard)
Billum v. State, 151 P.3d 507 (Alaska App.2006) (sentencing review limitations in multiple offenses)
Moore v. State, 123 P.3d 1081 (Alaska App.2005) (judicial approach to multiple convictions)
Allain v. State, 810 P.2d 1019 (Alaska App.1991) (multi-offense sentencing considerations)
Chaney v. State, 477 P.2d 441 (Alaska 1970) (original Chaney sentencing goals)