The Appellate Group

State v. Blake

State v. Blake, 2025 UT 21 (Durrant, C.J.)

Criminal

The Utah Supreme Court held:

  • The district court did not err when it held a second restitution hearing after the court of appeals reversed a restitution order but remained silent about remand proceedings.
  • Practice tip: The law of the case doctrine, not res judicata, applies to claims or issues relitigated in the same case. 
  • Practice tip: A reversal of a trial court order invalidates that order but does not prohibit further proceedings unless the reversing court expressly states otherwise.

Read the full court opinion