Wacey John Chabot was convicted of attempted murder and domestic battery with a deadly weapon after shooting his ex-fiancée Vanessa Aldrich in the head and beating their landlord Alejandro Martines with a gun during a confrontation at a trailer park in Sparks, Nevada. Chabot maintained he acted in self-defense, but the trial court prevented him from presenting evidence that Aldrich had stabbed him twice during their relationship—once underneath the ribs several years earlier and once in the hand the day before the shooting.
The Nevada Supreme Court found the trial court's exclusion of this evidence was error, as Chabot was entitled to present evidence of the victim's specific violent acts to show his state of mind. "A defendant who knows of the victim's previous violent acts may introduce evidence of them to show that the defendant was afraid of the victim and to corroborate the reasonableness of the defendant's belief in the need to use force in self-defense," Justice Stiglich wrote, citing the court's precedent in Burgeon v. State. The court held that such evidence could be presented "through the defendant's own testimony, through cross-examination of a surviving victim, and through extrinsic proof."
The court issued particularly strong language in describing the strength of the prosecution's case, noting that Chabot had "disabled the security cameras," "lured Martines and Aldrich back to the trailer through incessant texts and phone calls," and upon their arrival "locked the door, pulled out a gun, said 'all three of us are going to die tonight,' and initiated an altercation." Justice Stiglich observed that Martines testified Chabot "was the initial aggressor and that Chabot beat him in the head with the firearm and shot Aldrich in the face unprovoked."
The case reached the Nevada Supreme Court after Chabot was convicted following a four-day trial in Washoe County's Second Judicial District Court under Judge Scott N. Freeman. During pretrial hearings, Chabot had moved to introduce evidence of Aldrich's prior violent acts against him, offering text messages and medical records as proof. The trial court denied the motion, ruling that evidence of the stabbings was inadmissible as to Chabot's state of mind without explaining what foundation was required.
Chabot's defense team argued that his blood found on a kitchen knife and his visible injuries—including a "deep gash on his forearm" and wounds on his "neck and rib cage"—demonstrated he had been attacked first. The court rejected this reasoning, finding Chabot's theory of self-defense "relied on attenuated inferences." Justice Stiglich wrote that "although Chabot met the low standard necessary to introduce evidence of Aldrich's previous specific acts, admission of those acts would not have substantially strengthened Chabot's theory."
The unanimous court clarified an important procedural point for future cases, holding "that a defendant may present such evidence of a victim's specific violent acts even when the defendant elects not to testify at trial." This ruling extends the court's prior decision in Daniel v. State, which established that defendants asserting self-defense may introduce evidence of victims' prior violence if the defendant knew of those acts at the time of the incident.
The court also rejected Chabot's arguments that his police interview should have been suppressed and that the jury should have received an instruction on accidental discharge. On the latter point, Justice Stiglich found "not even a scintilla of accident in this case," noting that while the timeline was disputed, "a murky timeline does not alone support the theory that Chabot accidentally fired his gun." The court applied harmless error analysis, concluding the evidentiary errors "did not contribute to the verdict" given the strength of the prosecution's case.