State v. Z.M.

Summary

The court affirmed Z.M.'s convictions and sentence, holding that the district court adequately investigated and properly denied his request for substitute counsel, and that counsel's sentencing performance did not constitute a complete denial of counsel. The court found no prosecutorial misstatements, but held that the murder instructions and verdict forms did not adequately explain the alternative theories of first-degree murder and the possibility of a combined-theory verdict; because the jury unanimously found guilt under both theories, the instructional error was not clearly erroneous. The court also held that the aiding-and-abetting instruction was legally sufficient and that no cumulative error required reversal.