State v. Garcia-Mejia, 402 P.3d 82

Defendant Angel Garcia-Mejia was convicted by a jury of one count of sodomy on a child and eight counts of aggravated sexual abuse of a child for sexual acts against five of his six children.
Multiple children (five) testified to repeated sexual contact: oral contact involving Son, penis touching boys’ buttocks (over or under clothing), manual touching of genitals, and contact of Sister’s breasts. Many incidents occurred during shared bed or showering.
Mother separated the children after Son disclosed abuse; five children then reported abuse and the State charged nine counts.
Defendant denied most accusations, offered an alternative account that another child pushed Son onto his erect penis under a blanket, and conceded some contact (shared showers/roughhousing).
At trial the court denied Defendant’s motions for directed verdict, the jury convicted on all counts, and Defendant appealed arguing insufficiency of the evidence and that victims’ testimony was inherently improbable or coerced.

Issue	State's Argument	Garcia-Mejia's Argument	Held
Sufficiency of evidence for sodomy on a child (oral contact)	Multiple witnesses (Son and Oldest) testified Defendant intentionally pushed Son’s head onto his penis; Defendant’s own account corroborated that Son’s mouth contacted Defendant’s penis	Evidence was inconclusive or contradicted: another child pushed Son’s head; Oldest’s testimony partially corroborates Defendant; inconsistencies among children and prior DCFS interviews showed no sexual disclosure; possible fabrication/coercion	Affirmed. Evidence sufficed to support intentional sodomy; jury credibility determinations stand and conflicting evidence does not require reversal
Sufficiency of evidence for aggravated sexual abuse (contact with buttocks/genitals, breasts)	Five children gave similar accounts of repeated touching, removal of clothing, and manual/genital contact; intent to arouse may be inferred from repeated similar acts and circumstances	Contact was incidental, nonsexual roughhousing; absence of direct evidence of erection or statements undermines sexual intent; allegations possibly coerced	Affirmed. Circumstantial evidence (multiple victims, similar acts, removal of clothing, repeated conduct) reasonably supports inference of intent to arouse or gratify sexual desire

State v. Howell, 649 P.2d 91 (Utah 1982) (jury may resolve conflicting evidence; appellate courts defer to credibility determinations)
State v. Robbins, 210 P.3d 288 (Utah 2009) (vacated conviction where witness gave numerous inconsistencies and patently false statements undermining credibility)
State v. Prater, 392 P.3d 398 (Utah 2017) (clarifies when appellate court may reassess witness credibility; distinguishes mere inconsistencies from patently false statements and lack of corroboration)
State v. Holgate, 10 P.3d 346 (Utah 2000) (standard for reviewing sufficiency of the evidence: view evidence in light most favorable to verdict and determine whether reasonable minds would have reasonable doubt)
State v. Pedersen, 802 P.2d 1328 (Utah Ct. App. 1990) (inconsistencies that do not affect material elements go to credibility for the jury)
State v. Whitaker, 374 P.3d 56 (Utah Ct. App. 2016) (intent to arouse may be proved by circumstantial evidence and inferred from acts and surroundings)
State v. Kazda, 545 P.2d 190 (Utah 1976) (jury prerogative to choose what evidence to believe)