State v. BHAG SINGH, 267 P.3d 281

Bhag Singh was convicted of sexual abuse of a child after a bench trial in Utah.
Singh appeals, challenging sufficiency of the evidence, CCTV testimony under Rule 15.5, and waiver of jury trial.
Two witnesses testified via closed-circuit television about Singh's touching and kissing the victims.
The trial court credited the victims' testimony over Singh's, and found intent to arouse or gratify sexually.
The court denied Singh’s challenges and upheld the conviction; sentencing was affirmed.
Singh argues ineffective assistance and procedural errors, but the court addresses the primary issues on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Insufficient evidence of intent	State argues evidence supports intent to arouse.	Singh contends lack of arousal intent; credibility issues undermine evidence.	Sufficient evidence supports intent; credibility weighed in favor of the State.
CCTV testimony under Rule 15.5	State complied with Rule 15.5 for CCTV witnesses.	State failed to show distress and misapplied CCTV procedures.	No plain error; lack of proven prejudice despite custodial procedure.
Waiver of jury trial	Waiver was knowingly, voluntarily, and intelligently made.	No colloquy or interpreter required; waiver not knowingly made.	Waiver valid under totality of circumstances; no plain error.

State v. Larsen, 999 P.2d 1252 (Utah App. 2000) (sufficiency review for bench trials; weight of evidence matters)
State v. Hughes, 253 P.3d 1118 (Utah App. 2011) (credibility determinations afforded deference to trial court)
State v. Davis, 711 P.2d 232 (Utah 1985) (standard for evaluating witness credibility on appeal)
State v. Hall, 946 P.2d 712 (Utah Ct. App. 1997) (inference of intent from conduct admissible)
In re Baxter, 399 P.2d 442 (Utah 1965) (trial court credibility considerations in non-jury trials)
State v. Hassan, 108 P.3d 695 (Utah 2004) (plain error standard and jury-waiver considerations)