State v. Blais, 458 P.3d 1143

Officer observed Blais, his daughter, and another man conducting about a dozen street drug transactions through a high-powered spotting scope from a nearby building; he saw twists exchanged and Blais hand a black twist to a buyer.
Officers arrested the three suspects; a black twist was seized from the buyer and two white twists were seized from a black-and-gray backpack that had been on Blais’s lap.
Forensic testing at the crime lab identified the black twist as heroin and the white twists as cocaine; lab protocol and a lab report were introduced at trial.
Blais testified he was only holding a backpack for his daughter and denied selling drugs; no DNA or fingerprint tests were done on the twists and Blais did not object to chain-of-custody at trial.
Jury convicted Blais of distribution (heroin), possession with intent to distribute (cocaine) — both enhanced to first-degree felonies based on a prior conviction — and a class C misdemeanor for giving false information; court sentenced concurrent five-years-to-life terms for felonies and one year for the misdemeanor.
Blais moved to reduce the felony degrees on mental-health grounds; the court denied the motion. The State concedes, and the court agrees, the one-year misdemeanor sentence exceeded the statutory maximum and must be corrected.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency to convict of distribution of heroin	State: Officer observed Blais hand a black twist to buyer; seized black twist tested positive for heroin; booking and lab protocol established.	Blais: No proof the black twist seized/tested was the exact item he handed the buyer; insufficient physical link.	Affirmed — evidence and reasonable inferences support distribution; no plain error in submitting to jury.
Sufficiency to convict of possession with intent to distribute cocaine	State: White twists were recovered from a black-and-gray backpack that was on Blais’s lap; lab identified cocaine.	Blais: No proof the tested white twists were the same items seized or that the backpack was his.	Affirmed — officer testimony and lab results support possession and intent findings.
Denial of motion to reduce felony degrees	State: Aggravating facts (dangerous drugs, dealing with daughter, prior failures on probation) justified first-degree convictions.	Blais: Court failed to adequately consider his mental-illness history and request for inpatient treatment.	Affirmed — no abuse of discretion; court considered relevant factors and denial was reasonable.
Illegal sentence for misdemeanor	State: (concedes) statutory maximum for class C misdemeanor is 90 days.	Blais: One-year sentence exceeded statutory maximum.	Reversed on sentencing count — remanded to correct misdemeanor sentence to statutory limit.

State v. Maestas, 299 P.3d 892 (Utah 2012) (standard of review for sufficiency of the evidence)
State v. Holgate, 10 P.3d 346 (Utah 2000) (plain-error preservation rule for sufficiency claims)
State v. Salt, 347 P.3d 414 (Utah Ct. App. 2015) (abuse-of-discretion review for motion to reduce degree of conviction)
State v. Thorkelson, 84 P.3d 854 (Utah Ct. App. 2004) (correctness review for illegal sentence)
Salt Lake City v. Carrera, 358 P.3d 1067 (Utah 2015) (standard for when juries may draw reasonable inferences)
State v. Moa, 282 P.3d 985 (Utah 2012) (presumption that trial court considered relevant sentencing factors)