State v. Jaramillo, 372 P.3d 34

Late-night crime spree (Apr 20, 2010): Jaramillo entered a grocery-store clerk’s car, held a knife to her throat, forced her to drive, stole her phone and cash, and later attempted additional robberies and vehicle theft; he was injured and hospitalized after being run over while on an SUV hood.
Charges and convictions: convicted by jury of two counts of aggravated robbery (first-degree), aggravated kidnapping (first-degree), aggravated assault (third-degree), possession of a dangerous weapon by a restricted person (third-degree), and criminal trespass (misdemeanor).
Defense strategy: trial counsel presented no opening statement or affirmative evidence; relied on cross-examination and argued voluntary intoxication/erratic behavior but was not permitted to present expert testimony that Jaramillo had ingested a large amount of Xanax.
Rule 23B filings: on appeal Jaramillo sought a Rule 23B remand with affidavits and records (emergency visit prescribing 15 Xanax pills, hospital toxicology showing benzodiazepine, behavioral assessment, a later forensic psychologist’s report) to support an ineffective-assistance and voluntary-intoxication theory.
Sentencing: trial court imposed the statutory 15-years-to-life minimum on the aggravated kidnapping count; Jaramillo argued the court failed to perform the interests-of-justice analysis (proportionality and rehabilitation) required by Utah Code § 76-5-302 as interpreted in LeBeau.

Issue	Plaintiff's Argument (Jaramillo)	Defendant's Argument (State)	Held
Rule 23B remand / ineffective assistance: trial counsel failed to investigate/present evidence of acute Xanax intoxication that would negate mens rea	Counsel failed to investigate and present exculpatory evidence (emergency records, toxicology, expert report) showing Jaramillo was so intoxicated he could not form requisite intent	Evidence proffered is speculative for negating specific intent; record lacks instances showing counsel’s performance was deficient; new evidence not part of appellate record	Denied Rule 23B remand; ineffective-assistance claim on the merits rejected — proffered evidence did not show inability to form requisite mental states and the appellate record contains no specific proof of deficient performance
Sentencing: interests-of-justice analysis for aggravated kidnapping (15-to-life minimum)	Sentencing court failed to consider proportionality and rehabilitative potential; requested lower minimum (e.g., 6-to-life) and argued mitigating factors	Court argued it considered victim impact and that defendant understood actions; asserted sentencing discretion	Vacated sentence and remanded for resentencing under LeBeau: trial court must expressly consider proportionality and rehabilitation (interests-of-justice) when deciding whether to impose a lesser minimum term

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance: deficient performance and prejudice)
Honie v. State, 342 P.3d 182 (Utah 2014) (voluntary intoxication is viable only if it negates the mental state element required for the offense)
LeBeau v. State, 337 P.3d 254 (Utah 2014) (aggravated-kidnapping statute requires court to evaluate proportionality and rehabilitative potential in an interests-of-justice analysis)
State v. Lenkart, 262 P.3d 1 (Utah 2011) (counsel has duty to investigate but has discretion to make reasonable tactical decisions)
State v. Norton, 361 P.3d 719 (Utah Ct. App. 2015) (Rule 23B remand requirements; appellate court generally will not consider evidence outside the record to decide ineffective-assistance claims)