State v. Hatch
2025 UT App 132
Utah Ct. App.2025Background
- Ryan Scott Hatch and Alan Hamberlin claimed to have shot a wounded mule deer in Arizona that crossed into Utah, where they eventually found and field dressed it.
- Another hunting group reported witnessing the deer being shot and field dressed in Utah and alerted authorities, providing GPS evidence.
- Investigation found the deer carcass and tracks solely within Utah, along with bullet fragments and matching DNA from the carcass and a deer head found at Hatch and Hamberlin’s Arizona camp.
- Hatch was charged and convicted of assisting in wanton destruction of protected wildlife; he was acquitted of obstruction of justice.
- On appeal, Hatch argued his trial counsel was constitutionally ineffective for not objecting to destruction of evidence, failing to seek a continuance for expert testimony, and not objecting to evidence about border crossing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Destruction of Deer’s Heart Evidence | Counsel was ineffective for not objecting to the destruction of the deer’s heart, which might have been exculpatory. | Evidence would not have been exculpatory; no prejudice shown. | No deficiency; claim fails. |
| Continuance for Expert Rebuttal | Counsel should have sought a continuance to obtain a rebuttal expert after the State's late disclosure. | Counsel strategically chose experts and avoided battle of experts; no prejudice. | Reasonable strategy; no prejudice; claim fails. |
| Border-crossing Testimony | Counsel should have objected under rules of evidence to testimony on crossing the border without notifying wildlife authorities. | Testimony was relevant to consciousness of guilt and essential to defense theory. | Evidence properly admitted; no deficiency; claim fails. |
| Cumulative Error | Multiple claimed errors combined to warrant reversal. | No error to accumulate. | No error; claim fails. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (Standard for ineffective assistance of counsel: must show deficiency and prejudice)
- State v. Tiedemann, 2007 UT 49 (Framework for considering due process violations from destroyed evidence)
- State v. Scott, 2020 UT 13 (Objective reasonableness of counsel’s conduct)
- Archuleta v. Galetka, 2011 UT 73 (Defining prejudice for ineffective assistance of counsel)
- State v. Green, 2023 UT 10 (Criteria for admissibility of other-acts evidence)