The Appellate Group

State v. McClain

State v.McClain, 2025 UT App 150 (Tenney, J.)

Criminal

The Utah Court of Appeals held:

  • Defendant did not knowingly and intelligently waive his right to counsel.
  • The district court did not plainly err by failing to issue a directed verdict on the attempted rape of a child charge, and double jeopardy does not bar a retrial on that charge.
  • Practice Tip: Under Utah law, a defendant is not entitled to a hybrid representation (pro se and appointed counsel) in a criminal case, but standby counsel is permitted.

Read the full court opinion