358 P.3d 341
Utah Ct. App.2015Background
- Police attempted to serve a probation-violation warrant on Boyfriend at his apartment; Valdez-Sadler answered and allowed entry the first time but Boyfriend was not present.
- A subsequent visit had Valdez-Sadler refuse entry and she informed officers Boyfriend was not home.
- Officers arrested Boyfriend for probation violation after discovering him in the apartment during the search.
- Valdez-Sadler was charged with obstruction of justice (class A misdemeanor) based on harboring or concealing Boyfriend with the intent to hinder the investigation.
- At trial, after the City rested, Valdez-Sadler moved for directed verdict; the court denied; a jury found her guilty; on appeal the conviction was reversed due to statutory interpretation issues over what constitutes a
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Boyfriend’s conduct could be prosecuted as a crime under obstruction of justice. | Valdez-Sadler (City) contend[ed] Boyfriend’s probation violation constituted the “conduct that constitutes a criminal offense.” | Valdez-Sadler argue[d] probation violation is not a crime, so harboring/ concealing him cannot hinder a criminal investigation under the statute. | Yes; the court held the conduct was not a criminal offense, so directed verdict should have been granted. |
Key Cases Cited
- State v. Hirschi, 167 P.3d 503 (Utah App. 2007) (directed verdict standard and review of trial court rulings on sufficiency)
- State v. Barrett, 127 P.3d 682 (Utah 2005) (statutory interpretation and harmony of provisions in the same chapter)
- State v. Watkins, 123 P.3d 209 (Utah 2018) (canons of construction and harmony with related statutes)
- Perry v. Pioneer Wholesale Supply Co., 681 P.2d 214 (Utah 1984) (principle that more specific statute governs over general when in conflict)