The Appellate Group

State v. Rendon

State v. Rendon, 2026 UT App 123 (Mortensen, J.)

Criminal

The Utah Court of Appeals held:

(1) The district court properly denied Defendant’s motions for a new trial and to arrest judgment because there was enough evidence to disprove his justification defense beyond a reasonable doubt and to support the instruction regarding an initial aggressor.
(2) Any error in failing to give a curative instruction based on the prosecutor’s likely misstatement of the law in closing argument was harmless.

Practice tip:

The court suggested that the plain language of the self- defense statute contemplates that a defendant can use deadly force to protect an initial aggressor in limited circumstances.

Read the full court opinion