The Appellate Group

State v. Marx

State v. Marx, 2026 UT App 109 (Oliver, J.)

Criminal Law

The Utah Court of Appeals held:

(1) The district court did not abuse its discretion in denying Defendant’s motion for a new trial because failure to provide body camera footage was not a Brady violation.

(2) Defendant did not meet his burden to show that counsel was ineffective.

Practice tip:

The State’s failure to disclose evidence cannot result in a Brady violation without a reasonable probability of a different outcome.

Read the full court opinion