State v. Landon, 326 P.3d 101

Defendant Shane Landon was convicted of obstruction of justice (Class A misdemeanor) and driving on a suspended/revoked license (Class C misdemeanor) and appealed.
Charge arose after Landon obstructed a U.S. Marshal attempting to serve a warrant for Landon’s cousin; Landon testified he thought the marshal’s phone call might be a joke and denied belief the caller was an officer.
The marshal testified Landon referenced statutes about harboring a fugitive; the cousin’s mother also urged Landon to bring the cousin to the marshals, undermining Landon’s claim of mistaken identity.
During cross-examination, after evasive answers from Landon, the trial court asked whether Landon had ever been arrested on a warrant; Landon said yes; the court then barred further inquiry into the nature or conviction status of that prior arrest.
Landon argued on appeal the trial court improperly admitted other-act evidence (prior arrest) under Utah R. Evid. 404(b) and that the admission was prejudicial; the State contended the limited evidence did not create prejudice.
The appellate court assumed error for argument’s sake but affirmed, holding Landon failed to show a reasonable likelihood of a different outcome absent the prior-arrest evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of prior-arrest testimony	State argued limited disclosure (only that he had been arrested on a warrant) was permissible impeachment/context and court curtailed further questioning	Landon argued testimony about his prior arrest was improper other-act evidence under Rule 404(b) and prejudicial	Assuming error, no reversible prejudice shown; conviction affirmed
Prejudice standard to overturn verdict	State argued any error was harmless because other evidence corroborated marshal’s version	Landon argued Leber requires reversal where prior-act evidence undermines credibility and could tip balance	Court applied harmless-error/likelihood-of-different-outcome test and found no reasonable likelihood of a different result
Comparability of prior acts	State: prior warrant arrest without details is less probative and less prejudicial than propensity evidence	Landon: prior arrest undermines his credibility about knowledge of warrants/serving	Court: unlike Leber, the prior arrest was not similar conduct and lacked details; less risk of unfair propensity inference
Scope of permissible impeachment	State relied on limited impeachment (and court’s prohibition of further inquiry)	Landon contended even the limited disclosure unfairly prejudiced jury	Court noted trial court limited probing and allowed only a question about dishonesty-related conviction; overall impact was minimal

State v. Houskeeper, 62 P.3d 444 (Utah 2002) (harmless-error standard for admission of evidence)
State v. Cruz, 122 P.3d 548 (Utah 2005) (prejudice element under plain-error doctrine requires reasonable likelihood of a more favorable outcome)
State v. Lafferty, 20 P.3d 342 (Utah 2001) (error is reversible only if harmful with a sufficiently high likelihood of a different outcome)
State v. Knight, 734 P.2d 913 (Utah 1987) (reversal requires undermining confidence in verdict)
State v. Leber, 246 P.3d 163 (Utah Ct. App. 2010) (admission of prior similar bad acts that tip credibility balance can warrant reversal)