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Thomas Randolph remains in prison in Nevada, serving 60 years to life for the murders of his wife, Sharon Causse Randolph, and Michael Miller, a handyman who was killed at Randolph’s home in 2008. Recent reporting in 2026 places him at Lovelock Correctional Center. Although his original conviction was overturned, he was convicted again at a retrial, and the Nevada Supreme Court later affirmed that judgment.
Netflix’s The Widower: ’Til Death Do Us Part, released in the United States on September 30, 2026, revisits the case. For viewers wondering why the “Black Widower” is still incarcerated after winning an appeal, the answer lies in what the court actually ordered: a new trial, not an acquittal.
The proceedings offer a practical example of how criminal appeals work, when prejudicial evidence can justify reversal, and why a successful appeal does not necessarily result in release.
Who Is Thomas Randolph, the “Black Widower,” and What Is His Case About?
Thomas Randolph is a Nevada man convicted of murdering his sixth wife, Sharon Causse, and Michael Miller, a handyman prosecutors alleged he hired to kill her. The nickname “Black Widower” refers to his history of six marriages and the deaths of four women he had married.
That nickname is a media description, not a criminal charge or a finding that he murdered four wives. The Nevada case discussed here concerns Sharon and Miller. Keeping that distinction clear matters because the use of allegations from an earlier marriage became central to his first appeal.
Who Were Thomas Randolph’s Six Wives?
Thomas Randolph’s wives were Kathryn Thomas, Becky Gault, Leona Stapleton, Gayna Allmon, Francis Randolph, and Sharon Causse.
| Wife | Connection to the Case Background |
|---|---|
| Kathryn Thomas | First wife; their marriage ended in divorce. |
| Becky Gault | Second wife; evidence about her death became an issue in the Nevada appeal. |
| Leona Stapleton | Third wife; divorced Randolph and later died of cancer. |
| Gayna Allmon | Fourth wife; their marriage ended in divorce. |
| Francis Randolph | Fifth wife; died after heart surgery. |
| Sharon Causse Randolph | Sixth wife; her killing was part of the Nevada prosecution. |
These marriages and their different outcomes are documented in reporting about the case.
The different circumstances should not be combined into a claim that all four deaths were murders. For the appellate issue, the relevant distinction is between the charged Nevada offenses and evidence about events in Utah involving Becky.
What Happened to Sharon Randolph and Michael Miller in Las Vegas?
Sharon Randolph and Michael Miller were killed at the Randolph home on May 8, 2008. Randolph said an intruder had shot Sharon and that he then shot the intruder in self-defense.
Prosecutors presented a different account: Randolph arranged for Miller to kill Sharon during a staged home invasion so he could collect insurance proceeds, then killed Miller. Miller had worked as a handyman and was known to Randolph.
The case, therefore, involved more than deciding who fired a weapon. The prosecution sought to establish a planned killing and Randolph’s criminal responsibility for both deaths.
What Was Thomas Randolph Originally Convicted Of?
A jury convicted Thomas Randolph in 2017 of conspiracy to commit murder and two counts of first-degree murder with a deadly weapon. Death sentences followed.
That judgment led to the first appeal. The defense challenged the trial proceedings, including the admission of evidence connected to Becky’s death.
Why Was Thomas Randolph’s First Murder Conviction Overturned?
On December 10, 2020, the Nevada Supreme Court reversed Thomas Randolph’s 2017 convictions for conspiracy to commit murder and two counts of first-degree murder. The court ruled that the trial judge had improperly admitted prior-bad-act evidence concerning events surrounding the 1986 death of Randolph’s second wife, Becky, in Utah.
The court found that the danger of unfair prejudice substantially outweighed the evidence’s probative value. It also concluded that the State had not met its burden of showing that the error was harmless. The court therefore reversed the judgment and ordered a new trial.
What Did Becky Gault’s Death and Eric Tarantino’s Testimony Have to Do With the Appeal?
Becky, Randolph’s second wife, died from a gunshot wound in Utah in 1986. Randolph was later charged with her murder, but a Utah jury acquitted him in 1989.
Eric Tarantino, a former friend of Randolph, told authorities that Randolph had discussed recruiting him to kill Becky, allegedly to obtain life insurance proceeds. The Utah proceedings also involved allegations that Randolph tried to arrange Tarantino’s killing before Tarantino could testify against him. Randolph pleaded guilty to felony witness tampering in connection with that matter.
During Randolph’s Nevada trial, prosecutors introduced testimony about these Utah events to support their case concerning Sharon’s death and Michael Miller’s killing. The Nevada Supreme Court found that the trial evidence went beyond the limited prior acts the trial court had approved. It also included allegations of violence and other misconduct that risked portraying Randolph as a person likely to commit murder because of his character.
Randolph’s acquittal of Becky’s murder was also relevant to the court’s assessment of the evidence’s strength and potential prejudicial effect.
The Utah evidence therefore raised a central question in Randolph’s appeal: could prosecutors use allegations concerning Becky’s death to help prove the Nevada charges without encouraging jurors to infer guilt from his past? Nevada’s rules on prior-bad-act evidence govern that distinction.
What Is Prior-Bad-Act Evidence, and When Can a Court Admit It?
Prior-bad-act evidence is evidence of other alleged crimes, wrongs, or misconduct apart from the offense currently being tried. Under Nevada Revised Statutes § 48.045(2), this evidence generally cannot be used simply to suggest that a defendant has a criminal character and therefore committed the charged offense.
Nevada law may permit prior-bad-act evidence for a specific purpose, such as establishing motive, intent, preparation, plan, knowledge, or identity. However, the party offering the evidence must satisfy the applicable evidentiary requirements.
Under NRS 48.035, relevant evidence may be excluded when its probative value is substantially outweighed by the danger of unfair prejudice, among other specified concerns.
In Randolph’s case, the Nevada Supreme Court held that the danger of unfair prejudice from the Utah evidence substantially outweighed its probative value. That finding established the evidentiary error, but the court still had to decide whether the error was harmless or required a new trial.
Why Did the Improper Evidence Lead to a New Trial for Thomas Randolph?
Finding that the Utah evidence was improperly admitted did not automatically require reversal. The next question was whether the error had a substantial and injurious effect or influence on the jury’s verdict. This harmless-error analysis connected the court’s evidentiary ruling to its decision on whether Randolph should receive a new trial.
In its 2020 decision, the Nevada Supreme Court concluded that the State had not met its burden of demonstrating that the improper admission of the prior-bad-act evidence was harmless. The court therefore reversed the convictions and remanded the case for a new trial.
Randolph’s appeal illustrates why a challenge to trial evidence involves more than arguing that jurors should not have heard it. When reviewing a criminal conviction, appellate counsel may examine:
- The trial court’s ruling: Whether the court applied the correct legal standard when admitting or excluding evidence.
- The objection and record: Whether the issue was preserved and supported by the transcripts, exhibits, and court orders.
- The standard of review: How the appellate court evaluates the challenged decision.
- The effect of the error: Whether the error meets the applicable standard for reversal or other relief.
These considerations connect the evidentiary issue to the remedy sought on appeal. Counsel must evaluate both whether a legal error occurred and whether its effect on the proceedings supports relief.
Brownstone Law’s criminal appeals attorneys review trial rulings, preserved objections, and the appellate record when assessing potential challenges to criminal convictions and sentences.
Why Could Thomas Randolph Be Retried After His First Conviction Was Overturned?
Thomas Randolph could be retried because the Nevada Supreme Court overturned his first conviction due to trial error, not because he was acquitted or the prosecution’s evidence was legally insufficient. In December 2020, the court ruled that the trial judge improperly admitted prejudicial prior-bad-act evidence and ordered a new trial in Randolph v. State.
The Fifth Amendment’s Double Jeopardy Clause generally allows a retrial when an appellate court reverses a conviction because of trial error. However, if a court reverses a conviction because the prosecution presented legally insufficient evidence, the government generally cannot retry the defendant for the same offense. An acquittal also generally bars another trial for that offense.
| Legal Outcome | General Effect on a Subsequent Trial |
|---|---|
| Conviction reversed because of trial error | A retrial is generally permitted. |
| Conviction reversed for legally insufficient evidence | Retrial for the same offense is generally barred. |
| Acquittal by a jury or judge | The defendant generally cannot be retried for the same offense. |
| Sentence vacated while the conviction remains valid | Further sentencing proceedings may be required; a new trial on guilt is not ordinarily necessary. |
These distinctions explain why an overturned conviction does not necessarily mean a defendant has been cleared of the charges. The reason for the reversal determines whether the prosecution can proceed again.
In Randolph’s case, the Nevada Supreme Court ordered a new trial rather than entering an acquittal. Prosecutors retried him, and a jury convicted him again in 2023. His first successful appeal, therefore, did not end the criminal case.
What Happened at Thomas Randolph’s Retrial and Sentencing?
A second jury convicted Thomas Randolph in August 2023 of conspiracy to commit murder and two counts of murder with the use of a deadly weapon in the deaths of Sharon Causse Randolph and Michael Miller. On April 4, 2024, a Nevada court sentenced him to an aggregate term of 60 years to life in prison.
Randolph maintained his innocence at sentencing and said he intended to appeal. Unlike his first trial, which resulted in death sentences, prosecutors did not seek the death penalty at the retrial.
The retrial resulted in a new conviction despite Randolph’s successful 2020 appeal. The earlier reversal addressed errors in the first trial; it did not prevent prosecutors from presenting their case again under the applicable court rulings.
What Does a Sentence of 60 Years to Life Mean?
A sentence of 60 years to life means the sentence has a 60-year minimum term and a possible maximum extending to the end of the prisoner’s life. It does not guarantee release after 60 years.
The actual release date, if any, depends on the judgment, applicable sentence calculations, and governing parole rules. The sentence alone does not establish when Randolph could be released, so an exact release date should not be calculated simply by adding 60 years to the April 2024 sentencing date.
What Is the Timeline of Thomas Randolph’s Murder Case?
| Date | Case development |
|---|---|
| May 2008 | Sharon Causse Randolph and Michael Miller were killed in Las Vegas. |
| 2017 | A jury convicted Randolph of conspiracy to commit murder and two counts of first-degree murder. He received death sentences. |
| December 10, 2020 | The Nevada Supreme Court reversed the convictions and ordered a new trial because of improperly admitted prior-bad-act evidence. |
| August 2023 | A second jury convicted Randolph following the retrial. |
| April 4, 2024 | The court sentenced him to an aggregate term of 60 years to life in prison. |
| August 31, 2026 | The Nevada Supreme Court affirmed the later judgment of conviction on appeal. |
The 2020 Nevada Supreme Court decision explains why the first conviction was reversed. The 2026 order of affirmance addresses Randolph’s appeal from the second conviction.
The two appeals involved different trial proceedings. The 2020 decision required a new trial because of evidentiary error; the 2026 decision upheld the judgment entered after the retrial.
What Did the Nevada Supreme Court Decide in Thomas Randolph’s 2026 Appeal?
On August 31, 2026, the Nevada Supreme Court affirmed Thomas Randolph’s judgment of conviction in case No. 88625. Randolph challenged seven aspects of the proceedings following his 2023 retrial, but the court found no error warranting reversal. His conviction and sentence, therefore, remained in place.
The court addressed the following issues in its official order of affirmance:
| Issue raised on appeal | Nevada Supreme Court’s decision |
|---|---|
| Right to a speedy trial | Randolph did not establish a violation of his speedy-trial rights. |
| Statements during a crime-scene walkthrough | The court found that his participation and statements were voluntary and upheld the denial of his motion to suppress them. |
| Attorney-client privilege | Randolph failed to establish that the State had obtained privileged information through improper interference with his attorney-client relationship. |
| Jury instructions | The evidence supported the alternative theories of liability reflected in the challenged instructions, so the court found no reversible error. |
| Attorneys participating in closing arguments | The trial court was not required to allow two defense attorneys to argue because the State had not sought the death penalty. The court also found no abuse of discretion in allowing different prosecutors to handle the State’s closing and rebuttal arguments. |
| Request for an evidentiary hearing | Nevada’s judicial-conduct rule did not give Randolph an established right to the requested hearing in his criminal proceedings. |
| Cumulative error | Because the court found no errors in the challenged rulings, there were no errors to combine to justify reversal. |
The Nevada Supreme Court ultimately affirmed the judgment. Its decision addressed the issues Randolph raised in his second appeal; it did not reopen the evidentiary question that had led to the reversal of his original conviction in 2020.
The distinction matters: Randolph’s first appeal resulted in a new trial, but his later appeal did not overturn the conviction obtained at that retrial.
Randolph’s two appeals illustrate an important distinction in criminal appellate law: winning an appeal does not necessarily end a prosecution, and losing an appeal does not automatically establish that every other legal remedy is unavailable. What happens next depends on the issues decided, the applicable filing deadlines, and whether a separate procedure permits further review.
This raises a broader question for defendants and their families: what legal options may remain after a criminal appeal is unsuccessful? Let’s understand them in detail.
What Legal Options May Exist After a Criminal Appeal Is Unsuccessful?
After an unsuccessful criminal appeal, a defendant may have limited opportunities to request rehearing, seek discretionary review from a higher court, or pursue separate post-conviction proceedings. Federal habeas corpus may also be available for certain federal claims involving state convictions.
However, these procedures serve different purposes. An appellate court’s decision to affirm a conviction does not automatically create grounds for another challenge.
The following options explain the general legal framework. They do not establish that Thomas Randolph has filed, intends to file, or qualifies for any particular proceeding following his August 2026 appeal.
Can a Defendant Request Rehearing After Losing a Criminal Appeal?
A petition for rehearing asks the appellate court to reconsider its own decision based on specific legal or factual grounds. It is not ordinarily an opportunity to repeat arguments the court has already rejected.
Under Nevada Rule of Appellate Procedure 40, rehearing may be available when the appellate court has overlooked or misunderstood a material fact or legal question, failed to properly consider controlling authority, or when a directly controlling new rule of law arises within the applicable filing period.
Nevada generally requires a petition for rehearing within 14 days after the appellate decision, unless the court orders a different period.
A defendant cannot assume rehearing remains available simply because the conviction was affirmed. The deadline, applicable grounds, and procedural history must be examined.
Can a Defendant Seek Post-Conviction Relief After an Unsuccessful Appeal?
Yes, post-conviction relief may provide a separate way to challenge a criminal conviction or sentence, but it is not a second opportunity to litigate every issue rejected on direct appeal.
A direct criminal appeal generally focuses on errors established in the trial-court record. Post-conviction proceedings may address certain constitutional claims requiring evidence outside that record.
For example, some ineffective-assistance-of-counsel claims involve questions about an attorney’s investigation, preparation, or decisions that cannot be fully evaluated from trial transcripts alone.
In Nevada, NRS 34.726 generally requires a state post-conviction petition challenging a conviction or sentence to be filed within one year after the appellate court issues its remittitur when a direct appeal was taken, unless the applicable requirements for an exception are met.
Importantly, this is not necessarily the same date as the appellate decision. Nevada law also restricts claims that could have been raised in earlier proceedings and imposes additional requirements on successive petitions.
An attorney must therefore examine whether a proposed claim is legally distinct from the issues already decided, whether it is procedurally permitted, and whether the filing deadline has been satisfied.
Brownstone Law’s post-conviction lawyers evaluate potential collateral claims, prior court decisions, and the procedural requirements that may affect further challenges to criminal convictions and sentences.
Can the U.S. Supreme Court Review a State Criminal Conviction?
The U.S. Supreme Court may review qualifying final state-court judgments involving federal legal questions, but a defendant does not have an automatic right to Supreme Court review after losing a state appeal.
Under 28 U.S.C. § 1257, the Court may review certain final state-court judgments when a qualifying federal question is involved.
A defendant ordinarily requests this review through a petition for a writ of certiorari.
Under the Supreme Court’s 2026 Rules, Rule 10, considerations favoring review include important unresolved questions of federal law or conflicts between relevant court decisions.
The Court does not ordinarily grant review merely because a defendant disputes the facts, disagrees with an appellate court’s conclusions, or believes state evidentiary law was incorrectly applied.
Rule 13 generally provides 90 days to file a certiorari petition after the relevant judgment or order, subject to rules concerning rehearing, extensions, and particular circumstances.
The distinction between the Nevada Supreme Court and the U.S. Supreme Court is important. A state supreme court’s affirmance does not automatically transfer the case into the federal Supreme Court.
Brownstone Law’s U.S. Supreme Court appeals attorneys evaluate potential federal questions, jurisdictional requirements, and whether a case presents legally supportable grounds for requesting discretionary review.
Is Federal Habeas Corpus Available After a State Criminal Appeal?
Federal habeas corpus under 28 U.S.C. § 2254 may allow a person held under a state-court judgment to challenge custody on federal legal grounds. However, federal habeas review is a separate proceeding, not another direct appeal.
A federal habeas petition may involve qualifying constitutional claims, but the petitioner generally must first exhaust available state-court remedies.
Under 28 U.S.C. § 2254, a federal court reviewing a claim previously decided on its merits by a state court applies demanding statutory standards.
There are also important time restrictions. 28 U.S.C. § 2244 generally establishes a separate one-year federal filing period, subject to statutory starting dates and tolling provisions. A properly filed state post-conviction proceeding may toll the federal limitations period while it is pending, but it does not automatically restart an expired period.
Federal habeas review is therefore different from:
- A direct appeal: Challenges reviewable errors in the conviction or sentencing proceedings.
- State post-conviction relief: Provides a separate state-law procedure for qualifying collateral claims.
- A petition for certiorari: Requests discretionary review by the U.S. Supreme Court.
- Federal habeas corpus: Challenges qualifying federal legal violations affecting custody under a state judgment.
Each procedure has separate jurisdictional requirements, deadlines, and limitations. Determining whether a claim belongs in state or federal court is an essential part of evaluating possible relief.
How Can an Appellate Lawyer Evaluate a Criminal Conviction or Sentence?
An appellate lawyer evaluates whether a criminal conviction or sentence contains a legally reviewable issue, what procedure applies, and whether the available record supports a request for relief.
Thomas Randolph’s appeals demonstrate why the distinction between an alleged legal error and an error warranting reversal matters. His 2020 appeal resulted in a new trial because of improperly admitted prejudicial evidence, while his 2026 appeal did not establish grounds for reversing the judgment following his retrial.
A meaningful appellate evaluation generally begins with the actual court record rather than news coverage, documentary accounts, or assumptions about the outcome.
Documents that may assist the review include:
- The judgment of conviction and sentencing order.
- Relevant trial transcripts, exhibits, and evidentiary rulings.
- Any notices of appeal and prior appellate briefs.
- Appellate opinions, orders, and remittiturs.
- Orders resolving post-trial or post-conviction motions.
- Information concerning relevant filing and decision dates.
An appellate attorney can use these materials to identify preserved issues, examine the applicable standards of review, determine whether procedural restrictions apply, and assess whether further legal remedies may be available.
Not every unfavorable ruling provides a valid basis for appeal or post-conviction relief. The legal analysis must account for the particular judgment, the claims previously presented, and the relief permitted under applicable law.
Discuss Your Criminal Appeal With Brownstone Law
A criminal conviction, lengthy prison sentence, or unsuccessful appeal can raise important questions about the remaining legal options.
Brownstone Law represents clients in state and federal appellate matters, including criminal appeals and appropriate post-conviction proceedings. Its attorneys evaluate court records, identify potentially reviewable legal issues, and assess the procedural requirements that may affect further challenges to convictions and sentences.
Whether you are considering an initial appeal or seeking to understand your options following an unfavorable appellate decision, obtaining a timely review of the judgment and procedural history is important.
Contact Brownstone Law’s appellate attorneys to discuss your conviction, sentence, or prior appeal and determine what legal options may be available.
Because appellate and post-conviction deadlines can be strict, seek guidance promptly rather than waiting for every transcript or document to become available.
Frequently Asked Questions (FAQs)
Q1. Where Is Thomas Randolph Now, and Is He Still Alive?
As of October 2026, Thomas Randolph is alive and remains incarcerated at Lovelock Correctional Center in Nevada. The 71-year-old, widely known as the “Black Widower,” is serving a sentence of 60 years to life for the 2008 murders of his sixth wife, Sharon Causse Randolph, and Michael Miller. Biography
Although Randolph’s original murder convictions and death sentences were overturned by the Nevada Supreme Court in 2020, that ruling granted him a new trial rather than an acquittal. A second jury convicted him in August 2023, and he received his current prison sentence in April 2024.
His subsequent appeal was also unsuccessful. On August 31, 2026, the Nevada Supreme Court affirmed the judgment following his retrial, leaving his convictions and sentence intact.
Therefore, Thomas Randolph is still in prison despite successfully overturning his first convictions. His case demonstrates why winning a criminal appeal does not necessarily mean a defendant will be released or that the prosecution has ended.
Q2. Is the Black Widower Documentary Based on a True Story?
Yes. The Netflix documentary The Widower: ’Til Death Do Us Part, released on September 30, 2026, is based on the real criminal case of Thomas Randolph, the Nevada man nicknamed the “Black Widower.” The case was also featured in NBC’s 2021 true-crime documentary series The Widower.
The documentaries examine Randolph’s six marriages, the deaths of several of his wives, the investigation into the 2008 murders of Sharon Causse Randolph and Michael Miller, and the criminal proceedings that followed.
However, viewers should distinguish between allegations presented in a documentary and facts established in court. Randolph was convicted of the murders of Sharon and Miller, but suspicions surrounding his other marriages do not establish that he was responsible for every death discussed.
The legal record also provides important context that documentary coverage may not fully explain. The Nevada Supreme Court overturned Randolph’s original convictions in 2020 because of improperly admitted prejudicial evidence. He was subsequently convicted again at a 2023 retrial, and the Nevada Supreme Court affirmed that judgment in August 2026.
The documentaries tell the story of the investigation, while the court decisions establish the legal findings, appellate rulings, and outcomes of Randolph’s criminal case.
Q3. Was Thomas Randolph found guilty?
Yes. Thomas Randolph was found guilty of conspiracy to commit murder and two counts of first-degree murder in connection with the 2008 deaths of his sixth wife, Sharon Causse Randolph, and Michael Miller. He was convicted twice, although his first convictions were overturned on appeal.
In 2017, a Nevada jury convicted Randolph, and he received death sentences. However, the Nevada Supreme Court reversed those convictions in December 2020 because the trial court had improperly admitted prejudicial evidence concerning the death of his second wife.
Randolph faced a retrial in August 2023, when a second jury again found him guilty. In April 2024, he was sentenced to 60 years to life in prison.
On August 31, 2026, the Nevada Supreme Court affirmed his convictions following the retrial, rejecting his appellate challenges.
Therefore, despite successfully appealing his original convictions, Thomas Randolph remains convicted of the murders of Sharon Randolph and Michael Miller and is serving his prison sentence.
