The Appellate Group

State v. Wilcox

State v. Wilcox, 2025 UT 31 (Durrant, C.J.)

Criminal

The Utah Supreme Court held: 

  • When reviewing a pretrial justification hearing, appellate courts review for correctness a district court’s conclusion that a defendant held an objectively reasonable belief that someone posed an imminent threat to others.
  • Courts evaluate defendants’ beliefs regarding self-defense or defense-of-others-claims—both the objective and the subjective components—as of the moment they used force. An alleged victim’s later use of force is irrelevant to what a reasonable person in the defendant’s shoes would have believed at the time she used force.

Read the full court opinion