The Appellate Group

State v. Ngoy

State v. Ngoy, 2025 UT App 106 (Christiansen Forster, J.)

Criminal

The Utah Court of Appeals held:

  • The district court did not err in denying Defendant’s motion for directed verdict. 
  • The district court did not plainly err in admitting expert testimony. 
  • Practice tip: The relevant question regarding witness identification is not whether the type of identification is, by definition, reliable, but instead, whether the circumstances surrounding a specific identification make it such that a jury could reasonably rely upon it. 

Read the full court opinion