State v. Garcia-Vargas Jr., 287 P.3d 474

Garcia-Vargas Jr. was convicted in Utah and appealed his convictions for aggravated robbery (two counts), robbery, and possession of burglary tools.
The offenses arose from an October 2009 home invasion where Garcia-Vargas and another man, Freddy, entered a house and demanded money and drugs from two residents, G.T. and R.S.
During the incident, Garcia-Vargas and Freddy assaulted the residents; items were stolen, including phones and other valuables.
Garcia-Vargas was apprehended nearby with burglary tools and multiple cell phones; a backpack with additional loot and tools was found near the scene.
The State pursued accomplice liability for aggravated robbery, and the district court refused requests to instruct on theft, assault, and aggravated assault as lesser included offenses; the jury convicted Garcia-Vargas of robbery (G.T.), aggravated robbery (R.S.), and possession of burglary tools.
Garcia-Vargas argued there was a rational basis to acquit on the greater offenses and convict on lesser offenses; the court ultimately held no such basis existed and affirmed the convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether lesser included offense instructions were warranted	Garcia-Vargas argues for theft, assault, and aggravated assault instructions	State contends no rational basis to convict lesser offenses	No error; no rational basis to acquit greater and convict lesser

State v. Baker, 671 P.2d 152 (Utah 1983) (adopts evidence-based standard for lesser included offenses)
State v. Kruger, 6 P.3d 1116 (Utah 2000) (overlaps and same-or-less-than all facts test for included offenses)
State v. Spillers, 152 P.3d 315 (Utah 2007) (requires rational basis and defense-friendly view for lesser included offenses)
State v. Sisneros, 631 P.2d 856 (Utah 1981) (accomplice liability presumes intent to commit the underlying offense)