ENGLE (JULIE) v. DIST. CT. (STATE) (CRIMINAL)

CourtNevada Supreme Court
DecidedApril 16, 2026
Docket89183
StatusPublished
Cited by1 cases

This text of ENGLE (JULIE) v. DIST. CT. (STATE) (CRIMINAL) (ENGLE (JULIE) v. DIST. CT. (STATE) (CRIMINAL)) is published on Counsel Stack Legal Research, covering Nevada Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ENGLE (JULIE) v. DIST. CT. (STATE) (CRIMINAL), (Neb. 2026).

Opinion

142 Nev., Advance Opinion Eo IN THE SUPREME COURT OF THE STATE OF NEVADA

JULIE ENGLE, No. 89183 Petitioner, vs. THE SECOND JUDICIAL DISTRICT = FILED COURT OF THE STATE OF NEVADA, IN AND FOR THE COUNTY OF APR 16 2026 WASHOE; AND THE HONORABLE BROWN

DAVID A. HARDY, DISTRICT JUDGE, CHÝ Di CLERK Respondents, and THE STATE OF NEVADA, Real Party in Interest.

Original petition for a writ of mandamus challenging a district court order denying a motion to set aside a judgment of conviction. Petition granted in part and denied in part.

Evelyn Grosenick, Public Defender, and Kathryn Reynolds, Chief Deputy Public Defender, Washoe County, for Petitioner.

Aaron D. Ford, Attorney General, Carson City; Christopher J. Hicks, District Attorney, and Kevin Naughton, Appellate Deputy District Attorney, Washoe County, for Real Party in Interest.

Randolph M. Fiedler, Federal Public Defender, Las Vegas; Goodwin Law Group, PLLC, and Charles R. Goodwin, Las Vegas, for Amicus Curiae Nevada Attorneys for Criminal Justice.

SUPREME COURT OF NEVADA

(0) 1947A BEFORE THE SUPREME COURT, EN BANC.

OPINION By the Court, CADISH, J.: Following petitioner Julie Engle's conviction for attempted residential burglary, the district court suspended Engle's sentence and placed her on probation. As conditions of probation, Engle had to complete a specialty court program and pay restitution. Engle successfully completed a mental health court program and moved the district court to set aside the judgment of conviction under NRS 176A.260(6)(a). After denying the motion because of Engle's failure to pay restitution, the district court dishonorably discharged her from probation. Engle claims that the economic hardship exception in NRS 176A.430(6) excused her from NRS 176A.260(6)(a)'s requirement that a probationer fulfill the terms and conditions of probation before having a conviction set aside. But while NRS 176A.430(6) excuses a probation violation for nonpayment of restitution when nonpayment is due to economic hardship, that provision does not relieve a defendant from the affirmative obligation to satisfy the restitution requirement to obtain a set- aside of the conviction under NRS 176A.260(6)(a). So, the district court did not manifestly abuse its discretion when it denied Engle's motion to set aside the judgment of conviction. Though writ relief is unwarranted as to the set-aside of Engle's conviction, Engle's economic hardship excused her failure to satisfy the restitution condition for purposes of an honorable discharge from probation under NRS 176A.850. Accordingly, we grant the petition in part to require Engle be granted an honorable discharge.

SUPREME COURT OF NEVADA 2 (0) 1947A

- FACTS AND PROCEDURAL HISTORY Engle was convicted of first-offense attempted residential burglary, a felony. In the judgment of conviction, the district court imposed a sentence of 24 to 60 months in prison, suspended execution of the sentence, and placed Engle on probation for 24 months. As probation conditions, the district court ordered her to coniplete a specialty court program and pay restitution in the amount of $800. Subsequently, the mental health court entered an order finding that Engle had successfully completed the program but returned Engle's case to the district court because of an unpaid balance with the Division of Parole and Probation, which included the restitution, as well as fees. In its review hearing letter, the mental health court found that Id]ue to the non- compliance with fees and restitution, Ms. Engle Completed, but did not Graduate from, the Mental Health Court program." In a separate order, however, the mental health court waived the payment of fines and fees totaling $678, finding that Engle had "insufficient income, property, or resources to pay." At a later hearing before the district court, Engle made an oral motion to set aside her conviction under NRS 176A.260(6)(a), asserting that a set-aside was required because she complied with the terms of probation by completing the specialty court program.' The State opposed the motion, arguing that while Engle completed the specialty court program, setting the

'The parties referred to NRS 176A.240 in the district court, which addresses the drug court program, rather than the mental health court program governed by NRS 176A.260. The statutory language pertaining to a set-aside of a conviction upon completion of a specialty court program is identical in both statutes. Engle completed mental health court, and the parties agree on appeal that NRS 176A.260 governs here. SUPREME COURT OF NEVADA 3 (0) I 947A conviction aside was inappropriate because Engle failed to comply with the financial obligations of her probation, including the payment of restitution. Engle pointed to her economic hardship, arguing that it should excuse her nonpayment pursuant to NRS 176A.430(6). The district court acknowledged that the mental health court had already determined that Engle suffered an economic hardship when it waived her fines and fees but questioned whether hardship resulting in a waiver of fees and fines in the specialty court applied to restitution, which was a condition of Engle's probation. Ultimately, the district court denied the motion, finding that Engle did not fulfill the conditions of probation because she failed to pay restitution and she was therefore ineligible to have her conviction set aside under NRS 176A.260(6)(a). The district court rejected Engle's argurnent that the set-aside of her case was mandatory under the statute and Kabew v. Eighth judicial District Court, 140 Nev. 184, 545 P.3d 1137 (2024). The district court opined, however, that Engle was entitled to an honorable discharge from probation because "that's a distinction from dismissal of the charge or a set aside [of the conviction]." Nevertheless, the court subsequently entered an order dishonorably discharging her from probation. Engle petitions this court for a writ of rnandarnus, challenging both district court decisions. DISCUSSION As the parties acknowledge, Engle has no statutory right to appeal from the district court's denial of her requests for honorable discharge and the setting aside of the judgment of conviction, and she thus lacks an adequate legal remedy, favoring consideration of her petition for writ relief. Kabew, 140 Nev.

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Bluebook (online)
ENGLE (JULIE) v. DIST. CT. (STATE) (CRIMINAL), Counsel Stack Legal Research, https://law.counselstack.com/opinion/engle-julie-v-dist-ct-state-criminal-nev-2026.