ERNEST ALDRIDGE v. THE STATE OF NEVADA (2025)

ORDER OF AFFIRMANCE

This is an appeal from a judgment of conviction, pursuant to a guilty plea, of two counts of misdemeanor theft. Eighth Judicial District Court, Clark County; Jennifer L. Schwartz, Judge.

Appellant Ernest Aldridge impersonated the Federal National Mortgage Association (Fannie Mae) and recorded fraudulent deeds to gain ownership of and access to multiple properties in the Las Vegas area. A Nevada grand jury indicted him in May 2019 on numerous counts of burglary, theft, and fraud. After years of delay, Aldridge reached a plea agreement with the State, which in 2023 filed an amended indictment charging Aldridge with two counts of misdemeanor theft. Consistent with the plea agreement, the district court stayed adjudication of those counts for one year, on the condition that Aldridge abide by specified “stay out of trouble” requirements, including that he “not undertak[e] any act to exercise control over or possession of the properties” and “compl[y] with all court orders” related to the properties.

In 2018, before Aldridge was indicted, Fannie Mae won a judgment against Aldridge in the United States District Court for the District of Nevada quieting title to residential real properties in its favor. In August 2023—during the year Aldridge's plea agreement required him to stay out of trouble—Aldridge filed a complaint against Fannie Mae in the United States District Court for the District of Nevada. In this complaint, Aldridge asked the federal court to vacate its 2018 judgment quieting title to the properties in Fannie Mae's favor and to dismiss that prior action for want of jurisdiction and fraud upon the court. He also sought damages, alleging he had been “deceived by the pretended cloud on titles to properties.” In September 2023, the federal district court dismissed Aldridge's complaint, held him in contempt of its 2018 judgment that had quieted title in Fannie Mae's favor, and deemed him a vexatious litigant. Subsequently, the state district court determined that Aldridge violated the stay-out-of-trouble order by suing Fannie Mae in federal court seeking to undo the judgment quieting title to the properties. It therefore entered Aldridge's guilty plea and adjudicated him guilty of two counts of misdemeanor theft, sentencing him to credit for time served, from which order Aldridge appeals.

Contract principles apply to plea agreements, Aldape v. State, 139 Nev. 388, 390, 535 P.3d 1184, 1188 (2023), and where the facts are not in dispute, contract interpretation is reviewed de novo, Lehrer McGovern Bovis, Inc. v. Bullock Insulation, Inc., 124 Nev. 1102, 1115, 197 P.3d 1032, 1041 (2008). Though the State characterizes this case as a revocation of deferred adjudication and urges an abuse of discretion review, there is no reason to deviate from Nevada law applying contract principles to the interpretation of plea agreements. The facts are not in dispute and the sole question is whether Aldridge, by filing his 2023 federal court complaint, violated the terms of his plea agreement.

Aldridge contends the stay-out-of-trouble condition prohibited asserting control or possession of the properties, but it did not prohibit him from filing the complaint for damages where the properties had already been sold and obtaining control or possession over them is factually impossible. We disagree. The condition prohibited Aldridge from undertaking “any act to exercise control over” the properties. In his complaint, Aldridge sought damages based on his allegation that Fannie Mae “deceived” him through its “pretended cloud on titles to properties.” But Aldridge's complaint also asked the federal court to vacate the 2018 judgment quieting title in Fannie Mae's favor. This judgment meant that Fannie Mae owned the properties, free and clear of the bogus deeds purporting to vest title in Aldridge. The fact that Fannie Mae had sold the properties in the interim does not make Aldridge's quest to vacate the quiet-title judgment any less an assertion of control over the properties. Had the federal court vacated its 2018 quiet title judgment as Aldridge asked it to do in his 2023 complaint, his bogus deeds would once again cloud title to the properties. The district court correctly concluded that in seeking such relief from the federal court, Aldridge thereby violated the stay-out-of-trouble condition in his plea agreement with the State.

Accordingly, we

ORDER the judgment of the district court AFFIRMED.

Pickering, J.

Cadish, J.

Lee, J.