CRIMINAL LAW
Court of Appeals of Alaska (2023)
Johanna Crisman
In Morrissette v. State, 524 P.3d 803 (Alaska Ct. App. 2023), the court of appeals held the State met its burden to reach a first-degree murder conviction of Morrissette and that the sentence was reasonable given the record. (Id. at 808). Morrissette was convicted of first-degree murder and received a composite sentence of 99 years. (Id. at 804). Morrissette appealed his conviction, arguing the State did not produce sufficient evidence to convict him of first-degree murder because he did not have the requisite intent based on a methamphetamine-induced psychosis. (Id.). The court of appeals rejected this argument. (Id. at 806). At trial, the State produced evidence of Morrissette’s actions following the shooting, including evading the police, attempting to steal a vehicle, changing clothes, and interacting with police following the arrest. (Id.). This supported the State’s theory that Morrissette was not actively psychotic or otherwise incapable of forming the intent to commit murder. (Id. at 806). Morrissette additionally appealed his sentence length, 95 years for the murder conviction and 4 years for a related first-degree burglary charge, for a composite length of 99 years, arguing the length was excessive. (Id. at 806–07). The court of appeals determined that the superior court did not simply default to 99 years and further clarified that there is no default sentence for first-degree murders. (Id. at 808). Affirming the superior courts decision, the court of appeals upheld the first-degree murder conviction and determined the sentence fell within the range of reasonable sentences given the record in this case. (Id.).