Utah Case Summaries
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Coverage since January 6, 2026

Utah

UtahCriminalEvidenceIneffective Assistance of Counsel
Court of Appeals of Utah
Uncategorized

State v. Canal-Medina — Utah Rule 404(c) Requires No Similarity Between Prior Child Molestation Acts and Charged Offense

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The Utah Court of Appeals affirmed a conviction for aggravated sexual abuse of a child, holding that Utah Rule of Evidence 404(c) requires no similarity between prior child molestation acts and the charged offense for propensity evidence to be admissible, and that trial counsel was not ineffective for retaining a juror whose troubling statements during voir dire were followed by an audible chuckle and an express affirmation of the presumption of innocence.

UtahConstitutionalCriminalsearch-and-seizure
Court of Appeals of Utah
Uncategorized

State v. Saunders — Plain View Probable Cause Survives Absent Body Camera and Negative Field Tests

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The Utah Court of Appeals affirmed the denial of a motion to suppress evidence seized in plain view during a traffic stop, holding that an officer’s probable cause determination was reasonable under the totality of the circumstances even though the detective’s body camera was not recording and subsequent field tests on the seized baggie returned negative or inconclusive results.

UtahCriminalCriminal Proceduredomestic-violence
Court of Appeals of Utah
Uncategorized

Bluffdale City v. Verive — Brief Physical Impediment of a Preferred Exit Satisfies Utah’s Unlawful Detention Statute

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The Utah Court of Appeals affirmed Aaron Verive’s four class B misdemeanor convictions for unlawful detention and domestic violence in the presence of a child, holding that momentarily blocking a preferred exit—whether a doorway or a vehicle—satisfies the unlawful detention statute regardless of duration or alternative routes, and that events immediately following the charged acts were intrinsic evidence outside Rule 404(b)’s other-acts exclusion.

UtahCriminalCriminal ProcedureEvidence
Court of Appeals of Utah
Uncategorized

State v. Talbert — Utah Court of Appeals Rejects Variance, Rule 404(b), and Ineffective-Assistance Challenges to Sexual Abuse Convictions

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The Utah Court of Appeals affirmed six sexual-abuse convictions, holding that uncharged grooming conduct is admissible as intrinsic evidence outside Rule 404(b), that a charging variance between the information and the acts proven at trial raises sufficiency and notice issues—not jurisdictional ones—and that failure to seek a trial continuance upon discovering the variance waives procedural-due-process claims.

UtahCriminalCriminal ProcedureEvidence
Court of Appeals of Utah
Uncategorized

State v. Kent — Utah Court of Appeals Affirms Enticement Conviction Despite Undercover Officer’s Adult Photos and Voice

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The Utah Court of Appeals affirmed a child enticement conviction, holding that the sufficiency-of-evidence inquiry is subjective—asking whether this defendant believed the persona was a minor—and that entrapment as a matter of law requires more than a realistic undercover persona; here, the defendant’s own texts and statements showed actual knowledge of the victim’s age and independent criminal initiative.

UtahAppellate ProcedureCriminalIneffective Assistance of Counsel
Court of Appeals of Utah
Uncategorized

State v. Perez — Jurors’ Brief Hands in Voir Dire Did Not Compel For-Cause Removal; Ineffective Assistance Claim Fails

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The Utah Court of Appeals affirmed convictions for aggravated burglary and related charges, holding that trial counsel was not ineffective in declining to challenge for cause three jurors who raised their hands to leading voir dire questions and then affirmed their ability to follow jury instructions in response to the prosecutor’s follow-up.

UtahCriminalRestitution
Court of Appeals of Utah
Uncategorized

State v. Curwick — Medical Evidence Plus UOVC Documentation Suffices to Establish Restitution Causation for Victim’s Mother

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The Utah Court of Appeals affirmed a restitution order for an aggravated kidnapping victim’s mother, holding that a medical form attributing her PTSD to the crime, her own written statements, and a UOVC restitution specialist’s declaration—taken together—provided sufficient evidence of proximate causation for her lost wages.

UtahCriminalIneffective Assistance of CounselPost-Conviction Relief
Court of Appeals of Utah
Uncategorized

Miranda v. State — Post-Conviction Court Erroneously Presumed Prejudice From Unanimity Instruction Failure; Convictions Reinstated

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The Utah Court of Appeals reversed a grant of post-conviction relief, holding that the post-conviction court improperly applied the Chadwick presumption of prejudice to an ineffective-assistance claim; under Strickland, Miranda failed to show a reasonable probability that a proper unanimity instruction would have changed the verdict.

UtahCriminalEvidenceIneffective Assistance of Counsel
Court of Appeals of Utah
Uncategorized

State v. Collard — Convictions Reversed After Counsel Failed to Redact Domestic-Violence Finding from Protective Order Exhibit

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The Utah Court of Appeals affirmed denial of a motion to arrest judgment on protective-order-violation convictions — holding that the State sufficiently proved the permanent order’s terms through testimony and a docket entry — but reversed all three convictions on ineffective-assistance grounds because defense counsel failed to seek redaction of a domestic-violence finding in the temporary protective order admitted as a trial exhibit, a finding the court had already ruled irrelevant and whose admission undermined confidence in the verdict.

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