ROBINSON (MAURICE) v. STATE (CRIMINAL)

── ROBINSON (MAURICE) v. STATE (CRIMINAL) ── Court: Nevada Supreme Court Date: May 21, 2026 Category: General 142 Nev., Advance Opinion IN THE SUPREME COURT OF THE STATE OF NEVADA MAURICE ROBINSON, Appellant, vs. THE STATE OF NEVADA, MAY 2 1 2026 _ Respondent. Appeal from a judgment of conviction, pursuant to a jury verdict, of 15 counts of exploitation of an older or vulnerable person, 15 counts of theft, and 1 count of neglect of an older or vulnerable person. Eighth Judicial District Court, Clark County; Christy Craig, Judge. Affirmed in part, vacated in part, and rernanded. Nancy M. Lemcke, Public Defender, and Shana S. Brouwers and William M. Waters, Chief Deputy Public Defenders, Clark County, for Appellant. Aaron D. Ford, Attorney General, Carson City; Steven B. Wolfson, District Attorney, and Austin Beaumont and Shanon Clowers, Chief Deputy District Attorneys, Clark County, for Respondent. BEFORE THE SUPREME COURT, STIGLICH, CADISH, and LEE, JJ. OPINION By the Court, STIGLICH, J.: Appellant Maurice Robinson was Lawrence Turner's caretaker for many years. Over several months, Robinson removed a total of $76,880 SUPREME COURT OF NEVADA 1947A <40 22  from Turner's bank account, in 120 transactions, and used the money to fund Robinson's gambling habits. He further failed to properly care for Turner's health. The State charged Robinson with 15 counts of elder exploitation; 15 counts of theft, aggregating the total amount stolen during each month Robinson accessed Turner's account; and 1 count of elder abuse. The jury ultimately convicted Robinson on all counts. On appeal, Robinson argues that, on these facts, charging him with multiple counts of elder exploitation and theft was improper. In our recent opinion, Smith v. State, 142 Nev., Adv. Op. 26, 587 P.3d 251, 264 (2026), we held that the unit of prosecution for elder exploitation is 1 count per victim; therefore, we vacate 14 of the 15 counts of elder exploitation. Further, with respect to the theft counts, NRS 205.0834 allows the State to aggregate the value of property stolen through acts "committed pursuant to a scheme or continuing course of conduct" in determining what grade of theft to charge. Here, Robinson committed the thefts in only a single scheme or course of conduct, and it was therefore improper to convict him of 15 separate counts of theft. We therefore vacate 14 of the 15 counts of theft. As Robinson's other appellate arguments do not result in reversal, we affirm in part, vacate in part, and remand. FACTS AND PROCEDURAL HISTORY Robinson lived with Turner, sharing a single trailer. His caretaking duties involved helping groom Turner, giving Turner his medication, and paying Turner's bills using funds from Turner's account. Two months before the events giving rise to this case, Turner was hospitaliz