State v. De La Rosa, 445 P.3d 955

Jose De La Rosa was convicted by a jury of possession of a controlled substance with intent to distribute and retail theft.
Through post-conviction counsel De La Rosa moved for a new trial under Utah R. Crim. P. 24, asserting five bases: (1) defective constructive-possession jury instruction; (2) improper admission of prior drug convictions; (3) juror misconduct (jurors discussed the case during a recess); (4) failure to sever the retail-theft count from the drug-count; and (5) trial counsel’s alleged failure to move to suppress evidence from a vehicle search (later apparently abandoned).
The trial court granted De La Rosa a new trial but issued a one-line order that did not state which ground(s) supported its decision.
The State appealed, arguing the trial court must state its reasons so appellate review can be meaningful, especially where legal conclusions are implicated.
The Court of Appeals concluded appellate review is hampered without the trial court’s rationale and remanded with instructions that the trial court identify and explain the ground(s) for granting the new trial.

Issue	State's Argument	De La Rosa's Argument	Held
Whether the trial court’s one-line order granting a new trial is sufficient for appellate review	The absence of stated reasons prevents meaningful appellate review; remand required for the trial court to identify its basis	Trial court’s record and conduct show it carefully exercised discretion; that should suffice	Court of Appeals: remand for the trial court to state and explain the grounds for the new-trial grant
Adequacy of the constructive-possession jury instruction	If the trial court relied on an instruction error, appellate courts must assess correctness and impact	Instruction was inadequate and warranted a new trial	Not finally decided; remand required so trial court can state if this ground supported relief
Admissibility of De La Rosa’s prior drug convictions	If the trial court relied on improper admission, appellate review must evaluate that legal ruling and its effect	Admission was prejudicial and warranted a new trial	Not decided on merits here; remand so trial court can specify whether this drove its decision
Juror misconduct (jury discussed case during recess)	Any prejudicial juror discussion could justify a new trial; trial court best positioned to assess impact	Juror discussion did not show prejudice; remedy not necessarily a new trial	Not decided on merits; trial court should state whether juror misconduct formed the basis for relief

State v. Billingsley, 311 P.3d 995 (Utah 2013) (trial court abused discretion when it granted new trial based on exclusion that was correct)
Crookston v. Fire Ins. Exch., 817 P.2d 789 (Utah 1991) (trial court should describe basis for granting new trial to avoid appellate speculation)
Saltas v. Affleck, 105 P.2d 176 (Utah 1940) (articulating need for record to show reasons for new trials)
State v. Maestas, 299 P.3d 892 (Utah 2012) (trial court is better positioned to assess impact of courtroom events on fairness)
ASC Utah, Inc. v. Wolf Mountain Resorts, LC, 309 P.3d 201 (Utah 2013) (district courts must explain basis when granting new trials; denial need not be explained)
Interstate Income Props., Inc. v. La Jolla Loans, Inc., 257 P.3d 1073 (Utah Ct. App. 2011) (appellate courts may require meaningful statement of basis for trial-court decisions)
State v. Serrano, 440 P.3d 734 (Utah Ct. App. 2019) (appellate presumption that district court exercised proper discretion)
State v. Topanotes, 76 P.3d 1159 (Utah 2003) (appellate courts may affirm on any sustainable ground appearing in the record)
State v. Petersen, 810 P.2d 421 (Utah 1991) (trial courts do not have discretion to misapply the law)
State v. Barrett, 127 P.3d 682 (Utah 2005) (abuse-of-discretion review can include review for legal error)