State v. Hutchings
2012 UT 50
| Utah | 2012Background
- Hutchings was convicted of aggravated assault and criminal mischief, with other charges acquitted.
- He had a romantic relationship with D.C. living in New York; Hutchings paid her Salt Lake City apartment rent.
- In April 2006 Hutchings kicked in a locked door, entered the apartment, grabbed D.C. by the neck, and choked her during a physical struggle.
- During the attack Hutchings stated he was going to kill D.C.; D.C. sustained a broken hand from the assault.
- The defense relied on D.C.'s initiation of the attack; the jury found Hutchings guilty of aggravated assault and criminal mischief but not aggravated burglary.
- On appeal Hutchings challenged jury instructions on aggravated assault; the court of appeals adopted the State’s interpretation of the statute and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mental-state requirement for aggravated assault | Hutchings contends the court of appeals erred by misreading 'intent to cause' serious injury. | Hutchings argues the two-part mental state requires actual intent to cause serious bodily injury, not merely an intent to act. | Statute requires actual intent to cause serious bodily injury; court of appeals erred. |
| Ineffective assistance of counsel | Hutchings claims counsel failed to object to potentially misleading instructions. | State argues no deficient performance or prejudice under Strickland. | Counsel's performance deficient but not prejudicial; no reversal. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes standard for ineffective assistance)
- Boyde v. California, 494 U.S. 370 (U.S. 1990) (juror instruction interpretation and deliberation considerations)
- State v. Lenkart, 262 P.3d 1 (Utah 2011) (strong presumption of reasonable trial strategy; Strickland standard)
- State v. Potter, 627 P.2d 75 (Utah 1981) (focus on precise instruction language for offenses)
- State v. Besendorfer, 568 P.2d 742 (Utah 1977) (need for actual intent to inflict serious bodily injury)
- State v. Howell, 554 P.2d 1326 (Utah 1976) (distinction between intent to act and intent to cause harm)
- State v. Peck, 542 P.2d 1084 (Utah 1975) (intent required to cause serious harm as element of aggravated assault)
- State v. Maestas, 652 P.2d 903 (Utah 1982) (jury instructions on intent definitions aligned with statute language)