State v. Doyle, 2018 UT App 239

On Christmas Eve 2010 at a family party, Doyle was introduced to Victim; after a brief tense exchange, Victim was knocked unconscious by a punch and then beaten while on the floor.
Victim sustained severe facial fractures requiring extensive surgery and continuing injuries; Girlfriend and other guests testified about the attack and Doyle’s subsequent aggressive conduct that night.
Doyle was charged with aggravated assault (second-degree felony) with an in-concert enhancement; he claimed self-defense at trial, testifying Victim raised a beer bottle threateningly and he hit Victim once.
The trial court denied Doyle’s motion for a directed verdict on sufficiency grounds and instructed the jury on self-defense; the jury convicted Doyle of aggravated assault but rejected the in-concert enhancement.
On appeal Doyle argued (1) the State failed to disprove self-defense because evidence was inconclusive/speculative, and (2) the court should have disregarded Girlfriend’s testimony as inherently improbable under Robbins; he also raised plain-error alternative.
The Utah Court of Appeals affirmed, finding Doyle preserved the general insufficiency claim but not the Robbins-based challenge, and holding the State presented sufficient evidence to disprove self-defense beyond a reasonable doubt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency to disprove self-defense	State: Some evidence and reasonable inferences supported conviction; jury decides credibility	Doyle: Evidence inconclusive/speculative; Victim looked away so no proof he didn’t threaten Doyle with bottle	Affirmed: Viewing evidence favorably to State, reasonable jury could reject self-defense
Preservation of sufficiency arguments	State: Doyle’s directed-verdict motion preserved his general insufficiency claims	Doyle: Motion preserved all specific insufficiency theories he now raises	Court: Preserved the general inconclusive/speculative sufficiency challenge, not new legal theories
Inherent-improbability (Robbins) challenge to Girlfriend’s testimony	State: Robbins inapplicable; credibility questions for jury	Doyle: Girlfriend’s testimony was inherently improbable and should be disregarded (no corroboration; injuries inconsistent)	Not preserved; even reviewed for plain error, court found no obvious and fundamental insufficiency and declined to discard her testimony
Plain error review	State: No plain error; jury credibility determinations appropriate	Doyle: If unpreserved, court committed plain error by relying on Girlfriend’s testimony	Denied: insufficiency not obvious/fundamental; conflicting testimony and medical evidence do not render testimony inherently improbable

State v. Gonzalez, 345 P.3d 1168 (Utah 2015) (standard for reviewing directed-verdict/sufficiency challenges)
State v. Robbins, 210 P.3d 288 (Utah 2009) (doctrine allowing disregard of inherently improbable testimony is narrowly applied)
State v. Prater, 392 P.3d 398 (Utah 2017) (plain-error and inherent-improbability review; jury ordinarily assesses credibility)
Salt Lake City v. Carrera, 358 P.3d 1067 (Utah 2015) (circumstantial evidence and reasonable-inference/speculation distinction)
State v. Ashcraft, 349 P.3d 664 (Utah 2015) (reasonable inferences from circumstantial evidence and limits on incredibility challenges)