In re A.D-C., 559 P.3d 984

A.D.-C. (ADC), a 16-year-old with only a learner permit, crashed his father's vehicle after taking a corner too fast, resulting in a rollover accident into a residential yard.
ADC admitted driving without a license but contested the reckless driving charge in juvenile court.
At the bench trial, two police officers testified about the crash site's physical evidence and their opinions on the cause, with some contested as allegedly improper expert testimony.
The juvenile court found ADC delinquent for reckless driving based on commission of three traffic violations during the incident.
ADC appealed, arguing improper admission of expert testimony and insufficiency of the evidence supporting his reckless driving adjudication.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of officers' opinion testimony	Officers gave improper, undisclosed expert opinions (esp. on skid/yaw marks)	Opinions were lay testimony or harmless if error	Most testimony admissible as lay opinions; any error on yaw marks was harmless
Sufficiency of evidence for reckless driving	Evidence inadequate for three separate violations; no "willful or wanton disregard"	Evidence supports either statutory basis for reckless driving	Evidence sufficient to affirm on "willful or wanton disregard" pathway

State v. Rothlisberger, 147 P.3d 1176 (Utah 2006) (articulates the test for lay vs. expert testimony for police witnesses)
State v. Ellis, 748 P.2d 188 (Utah 1987) (lay opinion testimony about physical evidence admissible)
State v. Hulse, 444 P.3d 1158 (Utah Ct. App. 2019) (lay opinion on physical evidence admissible if within common experience)
Bailey v. Bayles, 52 P.3d 1158 (Utah 2002) (appellate court may affirm on any legal theory apparent in the record)