State v. Goodrich, 372 P.3d 79

Goodrich pled guilty to two counts of second-degree Sexual Abuse of a Child and was sentenced to two consecutive 1–15 year terms, suspended to 365 days in jail and 36 months probation supervised by AP&P (moved to Oregon where local authorities supervised).
AP&P filed an order to show cause alleging four probation violations; defense counsel requested amendments to two allegations (viewed vs. possessed sexual stimulus; untruthfulness about leaving Oregon), and Goodrich admitted to the two amended allegations.
At the hearing Goodrich explained he fabricated violations to get returned to Utah because of disputes with his Oregon probation officer; the court found this aggravating and revoked probation, reinstating the original prison terms.
On appeal Goodrich alleged (1) ineffective assistance of counsel for failing to obtain Oregon supervision records and for an alleged conflict violating the duty of loyalty; (2) lack of timely/adequate notice of violations (plain error); and (3) cumulative error.
The court affirmed, concluding Goodrich could not show prejudice: his admissions controlled the outcome, evidence he sought either would not help or would have been aggravating, and any notice defect was not harmful.

Issue	Goodrich's Argument	State's Argument	Held
Ineffective assistance — failure to investigate/present Oregon supervision records	Counsel should have obtained Oregon documents that would rebut violations and show due-process defects	Even if counsel failed, Goodrich admitted violations so he cannot show prejudice; records would not have changed outcome	Rejected — no prejudice; claim fails under Strickland standard
Ineffective assistance — conflict/duty of loyalty	Counsel advocated against client by requesting amendments to allegations	Amendments reduced culpability and reflected Goodrich’s own condition for admission; counsel acted in client’s interest	Rejected — no actual conflict; no breach of loyalty
Adequacy of notice (plain error)	Lacked timely/adequate notice of claimed violations, depriving due process	Goodrich appeared, acknowledged reading allegations, participated, and cannot show prejudice	Rejected — any notice error not obvious and not harmful; no reversible error
Cumulative error	Combined errors require reversal	Even assuming errors, cumulative effect did not undermine confidence in outcome	Rejected — no prejudice from alleged or assumed errors

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
Dunn v. State, 850 P.2d 1201 (Utah 1993) (plain-error and cumulative-error standards)
Perea v. State, 322 P.3d 624 (Utah 2013) (cumulative-error doctrine)
Potter v. State, 361 P.3d 152 (Utah Ct. App. 2015) (denial of Rule 23B supplementation when ineffective-assistance claim lacks prejudice)
Brinkerhoff v. Schwendiman, 790 P.2d 587 (Utah Ct. App. 1990) (deficient notice not prejudicial if party appears and participates)
Cowdell v. State, 626 P.2d 487 (Utah 1981) (prejudice required for reversal based on notice defect)
Petersen v. State, 810 P.2d 421 (Utah 1991) (questions of law reviewed for correctness)
Orr v. State, 127 P.3d 1213 (Utah 2005) (due-process notice requirement in probation revocation proceedings)