State v. Hovinghoff
State v. Hovinghoff, 2025 UT App 108 (Mortensen, J.)
Criminal
The Utah Court of Appeals held:
- Defendant’s first claim of ineffective assistance failed because trial counsel did not perform deficiently in not objecting to the challenged voir dire questioning.
- Defendant did not show prejudice for the second ineffective assistance of counsel claim.
- Practice tip: Voir dire questions aimed at asking a juror to prejudge facts, rather than disclose bias, are not appropriate and should be avoided.