State v. Estes
State v. Estes, 2025 UT App 10 (Mortensen, J.)
Criminal
The Utah Court of Appeals held:
- The district court did not abuse its discretion when it determined that evidence of Defendant’s abuse was admissible under rule 403 of the Utah Rules of Evidence.
- The alleged victim’s testimony was not sufficiently inconclusive or inherently improbable such that reasonable minds would have entertained some reasonable doubt as to Defendant’s guilt.
- Practice tip: Testimony of abuse is sufficient to find by a preponderance of the evidence that the abuse occurred, even if the abuse was never prosecuted.
- Practice tip: A preserved general sufficiency motion does not necessarily preserve a specific inherent improbability claim for appeal.