State v. Sisneros
State v. Sisneros, 2022 UT 7 (Himonas, J., majority)
Criminal Law
Defendant stole a car in Weber County, and he was charged—and pleaded guilty to—felony theft by receiving in Utah County. A year later, Weber County charged Defendant with aggravated robbery for stealing the car. Defendant moved to dismiss under the Single Criminal Episode Statute, Utah Code § 7-1-402, which bars the State from subjecting a defendant to separate trials for multiple offenses arising from a single criminal episode. The district court denied his motion. The Utah Court of Appeals reversed, finding that the second charge was barred by the Single Criminal Episode Statute. On certiorari, the Utah Supreme Court affirmed, holding:
- “It is difficult to imagine a more obvious single criminal episode than stealing a car and driving away with it.” Both charges arose from a single criminal episode, including because the offenses were “closely related in time” and the offenses were “incident to an attempt or an accomplishment of a single criminal objective.” Additionally, the offenses were within the jurisdiction of a single court because any district court in Weber County had jurisdiction to hear both offenses. The State was therefore barred from bringing the subsequent charge for aggravated robbery against Defendant.