State v. Bryson, 427 P.3d 530

Victim obtained a three-year civil stalking injunction (Nov. 17, 2011) prohibiting Bryson from contacting or causing distress to her.
A FedEx package addressed to Victim and postmarked May 7, 2014, delivered to her workplace contained a letter signed "Harry" (Bryson's nickname) referring to Victim as his "wife" and containing religious and family references, including Book of Mormon quotes and references to Victim’s deceased father and grandfather.
Victim reported the letter; police arrested Bryson ten days later. Bryson admitted sending the letter and acknowledged awareness of the injunction.
Before trial Bryson moved to redact religious and family references from the letter as unfairly prejudicial; the district court denied the motion and questioned jurors about religious bias during voir dire, dismissing one juror for cause.
A jury convicted Bryson of second-degree felony stalking; he appealed arguing improper admission of letter content (Utah R. Evid. 401–403) and insufficient evidence due to alleged inherent improbability of Victim’s testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of letter contents	State: content shows identity and context, so relevant and probative	Bryson: religious and family references irrelevant and unfairly prejudicial under Rule 403	Denied redact; contents relevant to author identity and not unfairly prejudicial
Jury bias from religious content	State: court mitigated bias via voir dire and juror dismissal	Bryson: religious references could inflame jurors of LDS faith	Court found voir dire adequate and no undue tendency to decide on improper basis
Sufficiency of evidence	State: letter, package, postmark, and Bryson's admissions corroborate Victim	Bryson: Victim's testimony inconsistent and inherently improbable; interview lacked exact date; copy lost	Evidence sufficient; Victim's testimony not inherently improbable and corroborated by admissions and letter evidence
Weight of inconsistencies	State: inconsistencies are credibility matters for jury	Bryson: prior statements on injunction conflict with trial testimony suggesting fabrication	Court held inconsistencies do not render testimony inherently improbable; jury resolves credibility

State v. Miranda, 407 P.3d 1033 (Utah Ct. App. 2017) (standard of review for evidentiary rulings)
State v. Gulbransen, 106 P.3d 734 (Utah 2005) (relevance of inflammatory evidence despite alternative proofs)
Met v. State, 388 P.3d 447 (Utah 2016) (noting changes in authority cited)
State v. Florez, 777 P.2d 452 (Utah 1989) (prosecutor not required to accept stipulation in lieu of admissible evidence)
State v. Lucero, 328 P.3d 841 (Utah 2014) (definition of unfair prejudice under Rule 403)
State v. Killpack, 191 P.3d 17 (Utah 2008) (court must weigh danger of unfair prejudice, not mere damaging evidence)
State v. Robbins, 210 P.3d 288 (Utah 2009) (inherent improbability standard)
State v. Prater, 392 P.3d 398 (Utah 2017) (requirements for finding testimony inherently improbable)
State v. Menzies, 889 P.2d 393 (Utah 1994) (presumption that juries follow instructions)