The Utah Court of Appeals held:
(1) The admission of the victim’s testimony detailing prior bad acts was harmless because the State’s evidence of the protective order violation was overwhelming and because the pro se defendant initially elicited the abuse allegations himself during cross-examination.
(2) Even if the phrasing of a special verdict form improperly shifted the burden of proof concerning the element of cohabitant status, the error was harmless because the facts establishing cohabitation were completely undisputed by both parties at trial.