State v. Cooper, 2011 UT App 234

In 1997, Mary and Richard Pace acquired a 63% interest in property and pursued a quiet title action after title issues arose.
Rodney Rivers conducted a title search and filed the quiet title action; Judge Lynn Davis ultimately ruled for the Paces in January 2004.
On November 15, 2004, Defendant Jerry Cooper’s father recorded an 'Administrative Judgment' alleging the Paces, Rivers, and Judge Davis owed Cooper $4.2 million.
Cooper signed the Administrative Judgment, signaling he prepared and submitted it; Judge Quinn later ruled in July 2005 that the Administrative Judgment was a wrongful lien as to Judge Davis’s property.
In July 2005, the State charged Cooper with four counts of filing a wrongful lien; he was tried in January 2008, representing himself, and convicted on all four counts.
Cooper appeals, challenging jury instructions, sufficiency of evidence, and whether four counts were proper for one document.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the jury instruction about the Administrative Judgment was error	Cooper argues instruction improperly delegated facts to be found by the jury regarding the lien.	Cooper contends the instruction violated constitutional rights to jury fact-finding.	Invited error; because Cooper affirmed no objection, issue not reviewed for merits.
Whether there was sufficient evidence of a wrongful lien against Judge Davis	Evidence showed the Administrative Judgment created a lien on Judge Davis’s property.	Dispute over whether the lien identified a specific real property and sufficiency of proof.	Sufficient evidence supported the jury verdict; trial court did not plainly err.
Whether four separate convictions were proper for one document	One document could affect multiple interests; four counts may be appropriate.	Only one wrongful lien document was filed; should not yield four convictions.	No plain error; the trial court did not plainly err in sending four counts to the jury.

State v. Bryant, 965 P.2d 539 (Utah Ct. App. 1998) (standard of review for jury instructions)
State v. Halls, 134 P.3d 1160 (Utah Ct. App. 2006) (plain error review with invited error caveat)
State v. Casey, 82 P.3d 1106 (Utah 2003) (manifest injustice vs. plain error standard)
State v. Winfield, 128 P.3d 1171 (Utah 2006) (invited error doctrine application to pro se defendant)
State v. Geukgeuzian, 86 P.3d 742 (Utah 2004) (invited error doctrine and pro se defendant considerations)
State v. Maese, 236 P.3d 155 (Utah App. 2010) (invited error doctrine and waiver behavior by defendant)
State v. Saunders, 992 P.2d 951 (Utah 1999) (prosecutorial duty and invited error implications)
State v. Pedockie, 137 P.3d 716 (Utah 2006) (waiver of right to counsel and self-representation standards)
State v. Arguelles, 63 P.3d 731 (Utah 2003) (right to represent oneself and related waiver standards)
State v. Holgate, 10 P.3d 346 (Utah 2000) (plain error standard description and preservation rules)