State v. Ainsworth, 2017 UT 60

Background

On Dec. 24, 2011 Thomas Ainsworth drove across a median and caused a head-on collision that killed an 18‑month‑old and seriously injured the parents.
Methamphetamine was found in Ainsworth’s system. He was charged with three counts under Utah’s "measurable substance" statute (Schedule I/II drugs present while negligently operating a vehicle causing death/serious injury). Each count was charged as a second‑degree felony.
Ainsworth argued the measurable‑substance classification violated the Utah Constitution’s Uniform Operation of Laws Clause because the DUI statute (which requires impairment) treats comparable conduct as a lesser, third‑degree felony. He also argued the statutory prescription defense irrationally favors those with prescriptions.
The district court rejected the constitutional challenges; Ainsworth pled guilty to three second‑degree felonies and received three 1–15 year terms to run consecutively.
The Utah Court of Appeals held the measurable substance offense was a "lesser crime" (because it does not require proof of impairment), concluded the legislature lacked a rational basis to classify it more severely than DUI, vacated the convictions and remanded for third‑degree felony convictions, but affirmed the district court’s imposition of consecutive sentences.
The Utah Supreme Court granted certiorari, reversed the court of appeals as to the uniform‑operation rulings, upheld the consecutive sentences, and reinstated the district court’s judgments and sentences.

Issues

Issue	Plaintiff's Argument (Ainsworth)	Defendant's Argument (State)	Held
Whether classifying measurable‑substance offenses as second‑degree felonies while DUI‑based offenses are third‑degree violates the Uniform Operation of Laws Clause	It is irrational to punish defendants more severely for mere presence of a drug than for actual impairment; measurable‑substance offense is a "lesser" crime and must receive the lesser classification	The statutes are not duplicative: measurable‑substance requires presence of Schedule I/II drugs; DUI requires proof of impairment. Legislature rationally punished Schedule I/II presence more severely	Reversed court of appeals; upheld second‑degree classification (rational basis exists and statutes are not wholly duplicative)
Whether the prescription defense (treating prescribed use differently) violates the Uniform Operation Clause	No rational basis: prescription does not affect impairment, so distinction is arbitrary	Legislature rationally may treat prescribed use differently to deter illegal drug use and promote public safety	Rejected Ainsworth’s challenge; upheld prescription defense as rational (citing Outzen reasoning)
Whether consecutive sentences for the three convictions constituted an abuse of discretion	The court failed to adequately weigh mitigating factors and should have imposed concurrent sentences	District court considered required factors and acted within broad sentencing discretion	Affirmed: no abuse of discretion; sentencing court had wide latitude

Key Cases Cited

State v. Shondel, 453 P.2d 146 (Utah 1969) (articulates principle limiting prosecutor’s arbitrary choice where two wholly duplicative statutes classify same conduct differently)
State v. Williams, 175 P.3d 1029 (Utah 2007) (Shondel doctrine applies only when statutes are wholly duplicative)
State v. Arave, 268 P.3d 163 (Utah 2011) (no Shondel problem where each statute requires proof of an element the other does not)
Wasatch Cty. v. Okelberry, 179 P.3d 768 (Utah 2008) (standard of review for court of appeals correctness review)
State v. Bluff, 52 P.3d 1210 (Utah 2002) (district courts have wide latitude in sentencing; abuse where required factors not considered)
Met v. State, 388 P.3d 447 (Utah 2016) (addresses limits of Bluff on other grounds)