The Appellate Group

State v. Martinez

State v. Martinez, 2026 UT App 171 (Mortensen, J.)

CRIMINAL LAW

The Utah Court of Appeals held:

(1) The district court did not err in denying Defendant’s motion for a directed verdict because the State presented sufficient evidence to disprove beyond a reasonable doubt that Defendant acted in self-defense when he shot and killed the two victims.


Practice tip:

The Court of Appeals flagged, but declined to resolve, a tension in Utah case law over whether when reviewing the denial of a directed-verdict motion made at the close of the State’s case, an appellate court may consider defense evidence introduced after the motion was denied. The court stated it would welcome further briefing on the issue in a future case.

Read the full court opinion