State v. Valenciana

Summary

The court held that the district court improperly supplemented the premeditation instruction with incomplete language, but the error was harmless because the evidence overwhelmingly supported premeditation. It upheld the denial of a voluntary manslaughter instruction, found no prosecutorial error or abuse of discretion in denying a mistrial, and declined to apply cumulative-error review. The court vacated the sentence and remanded for resentencing because a reckless criminal-threat conviction was improperly included in the criminal-history score.