State v. Mancia; State v. Saedt; State v. Alvarez
State v. Mancia, 2026 UT App 30 (Oliver, J.)
State v. Saedt, 2026 UT App 30 (Oliver, J.)
State v. Alvarez, 2026 UT App 30 (Oliver, J.)
Criminal Law
The Utah Court of Appeals, on consolidated appeals in three cases,
held:
- Counsel did not provide ineffective assistance by (1) failing to argue for the inclusion of the legal definition of “recklessly” in the jury instructions because there is no theoretical factual scenario in which that failure permitted the jury to wrongfully convict; (2) failing to object to the formatting of the party liability instructions because the instructions were legally correct; (3) failing to object to a witness’s character/victim impact testimony because there is no reasonable likelihood that the jury would have acquitted the defendants but for this testimony; (4) failing to request a specific unanimity instruction because the jury could have convicted the defendants under different theories of liability; and (5) by failing to object to the prosecution of one of the defendants, a minor at the time, under the theory of party liability because the amendment limiting district court jurisdiction over minor to “principal actors” was substantive, not procedural, and as such, the amendment did not apply retroactively.
- The cumulative effect of any assumed errors does not undermine the confidence in the outcome of the verdict.