The Appellate Group

State v. Corona

State v. Corona, 2025 UT App 93 (Mortensen, J.)

Criminal

The Utah Court of Appeals held:

  • Counsel was not deficient in failing to file a motion for directed verdict based on a theory of inherent improbability. 
  • Defendant was not prejudiced by counsel’s failure to object to testimony under rule 403. 
  • Practice tip: The inherent improbability standard generally is not satisfied by the mere existence of a conflict in the evidence. Appellate courts have reversed only once under the inherent improbability standard. 

Read the full court opinion