State v. Deuel
State v. Deuel, 2026 UT App 8 (Christiansen Forster, J.)
Criminal
The Utah Court of Appeals held:
- The district court exceeded its discretion in admitting an entire toxicology report because the report’s mention of a specific “toxicity” level was likely to confuse the issues and mislead the jury into thinking that a test result far above that amount indicated significant impairment that would render a person incapable of safely operating a vehicle. This error was harmful.
- Judicial tip: A statement that raises some potential for criminal liability does not necessarily meet the requirement of the rule 804 hearsay statement-against-interest exception, particularly when one can readily conceive of self-serving motivations the declarant may have had to make the statement at issue.