## Facts

- Police stopped a vehicle; Taggart Parrish was a passenger and fled on foot.
- During pursuit, Parrish attempted to aim a handgun at an officer; the officer knocked it away, and Parrish struggled while repeatedly reaching for the gun.
- Police later found methamphetamine in the vehicle.
- Parrish pleaded guilty to (1) trafficking in a controlled substance and (2) resisting/obstructing a public officer with use of a dangerous weapon.
- Parrish sought a reduced or suspended trafficking sentence under NRS 453.3405(2), claiming he provided substantial assistance to law enforcement while jailed.
- The district court imposed a life sentence on the trafficking count without making express findings on whether Parrish rendered “substantial assistance” under the statute.

## Issues

1. Whether the district court abused its discretion under NRS 453.3405(2) by failing to make reviewable findings on substantial assistance and imposing the maximum sentence on an unclear record.
2. How a sentencing court must structure and record its discretionary decision-making when a defendant moves for relief under NRS 453.3405(2).

## Decision

- The Nevada Supreme Court vacated the trafficking sentence and remanded for a new sentencing hearing before a different district judge.
- The court held the record was too ambiguous to determine whether the district court (a) found no substantial assistance (making Parrish ineligible) or (b) found substantial assistance but denied relief as a discretionary matter.
- The convictions were left intact; only the sentence was disturbed.

## Legal Principles

- Under NRS 453.3405(2), a court may reduce or suspend a qualifying trafficking sentence only if it finds the defendant rendered substantial assistance in the identification, arrest, or conviction of others involved in trafficking.
- The statute requires a two-step approach: (1) determine eligibility by finding (or not finding) substantial assistance; (2) if eligible, decide in discretion whether to grant a reduction or suspension.
- Sentencing discretion under NRS 453.3405(2) is broad but not unlimited; the court must exercise discretion in a way that is reviewable on appeal.
- When the record does not reveal the basis for denying a substantial-assistance motion, the proper remedy is vacatur and remand for a new sentencing hearing, which may be ordered before a different judge to ensure a fresh exercise of discretion.

## Conclusion

Because the district court did not make clear findings showing whether Parrish was ineligible for relief or was eligible but denied relief in discretion, the appellate court could not conduct meaningful review; the life sentence was vacated and the case remanded for resentencing before a different judge.


Parrish v. State, 12 P.3d 953 (Nev. 2000)