CROCHET v. STATE (2026)

ORDER OF AFFIRMANCE

Sufficiency of the evidence

Crochet argues that there was insufficient evidence to support the convictions. He contends that the State failed to prove that he acted wantonly or that he knew or should have known there had been a collision.

In reviewing the sufficiency of the evidence, we must decide “if any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt when viewed in a light most favorable to the prosecution.” Acosta v. State, 141 Nev., Adv. Op. 40, 573 P.3d 1258, 1267-68 (2025) (internal quotation marks omitted). “It is the jury's role to determine the weight to give the evidence, and circumstantial evidence alone may sustain a conviction.” Id. at 1268.

The evidence at trial established that Crochet was driving a semitruck, failed to stop at a stop sign, and hit the victim who was walking in a crosswalk. Crochet continued driving with the victim's body wedged at the front of the truck before stopping on a freeway on-ramp and exiting the truck with a flashlight. After returning to the truck, Crochet backed up and swerved around the victim's body. In the aftermath of the accident, Crochet searched for “hit and run attorneys” and news of recent hit and runs on the internet. These facts, taken together, present sufficient evidence that Crochet drove with a “wanton disregard of the safety of persons,” NRS 484B.653(1)(a) (reckless driving), and knew or should have known an accident had occurred before he left the scene of the collision, NRS 484E.010 (duty to stop at scene of crash involving death or personal injury); Clancy v. State, 129 Nev. 840, 844, 313 P.3d 226, 229 (2013) (“NRS 484E.010 requires the State to prove that the driver either knew or should have known that he was involved in an accident.”).

Testimony narrating dash cam video

Crochet argues the district court erred in allowing a witness to narrate the truck's dash cam footage of the collision. The witness, who worked as the safety director for the trucking company that employed Crochet, described events in the dash cam footage after explaining how the footage approximately captured what Crochet would have seen while driving. Crochet contends that the witness's testimony about what Crochet would have seen while driving was speculative and an opinion on Crochet's guilt. We are not convinced the witness's testimony was a direct opinion that Crochet knew he had hit the victim. See Collins v. State, 133 Nev. 717, 725, 405 P.3d 657, 665 (2017) (“[I]nterpretation of the evidence by a witness, even though that interpretation may be important in establishing an element of the crime and thus leading to the inference of guilt, is not in the same category as an actual conclusional statement on the guilt or innocence of the accused party.” (internal quotation marks omitted)). But even if this testimony should have been excluded, we conclude no relief is warranted given the substantial evidence of Crochet's guilt. See NRS 178.598 (“Any error, defect, irregularity or variance which does not affect substantial rights shall be disregarded.”).

Jury admonishment

Crochet argues the district court erred in failing to admonish the jury to disregard potentially prejudicial evidence that was inadvertently introduced at trial. The State played video clips of Crochet's police interview to the jury and accidentally played a clip where Crochet said, “I haven't been in trouble for quite some time.” The district court discussed the issue with the parties and offered to admonish the jury to disregard the statement, and Crochet declined any admonishment. Because Crochet declined the district court's offer to admonish the jury regarding the issue, the error is invited and we will not reverse. Jones v. State, 95 Nev. 613, 617, 600 P.2d 247, 250 (1979) (recognizing that where a defendant participates in the alleged error, he is estopped from raising any objection on appeal).

Cumulative error

Crochet last argues that cumulative error deprived him of a fair trial. Because we discern only one error, “there is nothing to cumulate.” Belcher v. State, 136 Nev. 261, 279, 464 P.3d 1013, 1031 (2020). Accordingly, we

ORDER the judgment of conviction AFFIRMED.