The Appellate Group

State v. Camara (amended opinion)

State v. Camara, 2026 UT App 5 (Tenney, J.) (amended opinion)

Criminal

The Utah Court of Appeals held:

  • In an amended opinion, the Court added a new section addressing Defendant’s claim of ineffective assistance for failing to file a motion for a directed verdict on several counts. 
  • Counsel did not provide ineffective assistance because there was sufficient evidence to support the convictions. 
  • Practice tip: The court noted it is an “open question as to what the remedy should be in a case in which an appellate court concludes that the defendant received ineffective assistance because his or her trial counsel did not file what would have been a meritorious motion for a directed verdict based on the sufficiency of the evidence.” It invited future litigants to fully brief the issue “so that it can be definitely resolved.” 

Read the full court opinion