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SAKEAGAK v. STATE1/9/1998
William Arthur Sakeagak was convicted of first-degree murder, AS 11.41.100(a)(1)(A), and sentenced to 99 years' imprisonment. He appeals his conviction, arguing that three of the trial judge's evidentiary rulings were mistaken. Sakeagak also appeals his sentence; he argues that the judge was mistaken in finding that the victim was particularly vulnerable, and he further asserts that his 99-year sentence is excessive. We affirm.
At approximately 9:20 p.m. on Sunday, October 22, 1995, North Slope Borough police officers arrived at Quonset Hut 267A at the Naval Arctic Research Laboratory (NARL) outside of Barrow. They came to investigate the report of a possible death. The officers arrived to find Sakeagak kneeling over the body of his wife, Judy.
It was evident to the officers that Judy Sakeagak was dead. Rigor mortis had begun to set in, and the extremities of Ms. Sakeagak's body were already cool to the touch (although the body core was still warm).
William Sakeagak's breath smelled of alcoholic beverages, but he was responsive to questions and seemed to be in control of his faculties. Sakeagak told the officers that he had left home around 7:15 that evening (that is, approximately two hours before), and that Judy had been alive, sitting in the living room, when he left. According to Sakeagak, he returned home at 9:15 (just a few minutes before the officers arrived) and discovered his wife collapsed in the bedroom.
Sakeagak told the officers that, a week before, his wife had begun to suffer a heart condition. The officers noticed that there were several bloodstains in the bedroom, in the bathroom, and on Sakeagak's clothes. When asked about these bloodstains, Sakeagak first said that he didn't know where the blood had come from; later, he said that his wife had been suffering spontaneous nosebleeds.
As just explained, when Sakeagak was asked to describe his movements that Sunday evening, Sakeagak said that he had left his house around 7:15 and had returned around 9:15. Sakeagak told the officers that, during these two hours, he first visited the Recreational Center at NARL and then he took a bus into Barrow, where he went to a store and purchased soda and cigarettes. He then returned home.
The police later discovered that Sakeagak's account of his whereabouts did not match the bus schedule. On Sunday evenings, only two buses departed Barrow for NARL; one left at 5:40 p.m. and the other left at 9:40 p.m. The bus trip takes 15 minutes: that is, the earlier bus arrived at NARL at 5:55, while the later bus arrived at 9:55. If the buses were on time that evening, Sakeagak could not have taken the bus from Barrow and returned to NARL shortly after 9:00 as he claimed. Moreover, the police also found out that the NARL Recreational Center was closed on Sundays.
The medical examiner conducted an autopsy and concluded that Judy Sakeagak had died as a result of manual strangulation. Given the condition of the body when it was discovered, the medical examiner concluded that Judy Sakeagak had probably been dead for several hours when the officers arrived (at 9:20 p.m.). This information cast doubt on Sakeagak's claim that his wife had been alive when he left the house at around 7:15 that evening.
Upon receipt of the autopsy report, Sergeant Venable (one of the investigating officers) re-interviewed Sakeagak. During this second interview, Venable told Sakeagak that it appeared Judy did not die of natural causes, and that Sakeagak was responsible for her death. However, Venable did not tell Sakeagak that the medical examiner had concluded that Judy was strangled. Sakeagak eventually told Venable that he and Judy had f
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