The appellant, Philip Grandine, appealed his conviction for manslaughter and his 15-year sentence in the drowning death of his wife, Karissa Grandine.
This was his second trial, the first conviction having been overturned.
The appeal raised three grounds against conviction: error in leaving a criminal negligence by omission theory of liability to the jury without evidentiary basis, error in refusing to exclude evidence based on issue estoppel (computer searches for "autopsy"), and inadequate jury instruction on the use of the appellant's out-of-court statements.
The appellant also argued the sentence was excessive and based on an unproven aggravating factor.
The Court of Appeal dismissed both the conviction and sentence appeals, finding sufficient evidentiary basis for the criminal negligence theory, no issue estoppel error, and adequate jury instructions.
The court also found the sentence was fit and reasonable, rejecting the "almost murder" characterization argument and the breach of trust argument.
