State v. Bonds
State v. Bonds, 2023 UT 1 (Petersen, J.)
Bonds shot Williams in the back. At trial for murder, he claimed that he shot Williams because Williams had made threats to his family and was running toward their apartment. The State told the jury it was odd that Bonds never told officers that he was defending his family when he was initially arrested. The Utah Court of Appeals vacated his convictions, concluding Bonds had received ineffective assistance of counsel when trial counsel failed to object to the State’s use of his silence while being arrested and when trial counsel failed to object to a manslaughter jury instruction that incorrectly reversed the burden of proof applicable to imperfect self-defense. On certiorari, the Utah Supreme Court affirmed his convictions, holding:
- Bonds cannot show prejudice where Bonds was armed but Williams was not and where Bonds shot Williams in the back from ten feet away as he ran.