State v. Clara, 546 P.3d 963

Jon Michael Clara was driving his SUV in Salt Lake City when it was repeatedly rammed by a snowplow-equipped truck, spinning his SUV and causing airbags to deploy.
Clara believed his SUV was disabled and feared for the safety of his passenger, whom he thought might be injured and trapped.
After the snowplow appeared to start driving away, it suddenly stopped about fifty feet from Clara and began turning right, which Clara interpreted as a U-turn to attack again.
Clara fired seven warning shots in the direction of the snowplow; one bullet struck a nearby pickup truck, narrowly missing a child's head.
Clara was arrested and charged with seven counts of felony discharge of a firearm; he sought an evidentiary hearing under Utah’s Pretrial Justification Statute to assert self-defense pretrial.
The trial court dismissed charges after finding Clara made a prima facie claim of self-defense and the State failed to disprove it by clear and convincing evidence. The State appealed.

Issue	Appellant's (State's) Argument	Appellee's (Clara's) Argument	Held
Did Clara make a prima facie claim of self-defense under the Pretrial Justification Statute?	Clara’s belief was not objectively reasonable as the snowplow was not imminently threatening when shots were fired.	Clara reasonably and subjectively believed an imminent threat existed based on the snowplow's prior assaults and sudden maneuvering.	Yes; Clara made a prima facie claim of self-defense; the trial court did not err.

State v. Berriel, 2013 UT 19 (Utah 2013) (defined imminence in the self-defense context as an immediate and real threat)
State v. Sorbonne, 2022 UT 5 (Utah 2022) (self-defense necessity element has both subjective and objective components)
Bair v. Axiom Design, L.L.C., 2001 UT 20 (Utah 2001) (prima facie case standard is a question of law)
Brown v. United States, 256 U.S. 335 (1921) (expectation of detached reflection in moments of danger is unreasonable)