State v. Lantz, 424 P.3d 1094

Officer stopped a vehicle on I-15 for equipment and unsafe driving; vehicle had driver (Driver) and front-seat passenger Mark Lantz (Defendant), who was the registered owner.
Officer smelled burnt marijuana; Driver admitted both had recently smoked marijuana; neither occupant had a valid license.
Officer asked Defendant whether there were drugs; Defendant initially refused, then (per Officer) said they were in the car; Officer detained Defendant and searched the vehicle.
Search recovered methamphetamine, marijuana, drug paraphernalia, and about $2,000 cash on Defendant; Officer testified Defendant admitted ownership of some paraphernalia and assented that the money was drug-related; Defendant disputed those statements at trial.
Defense counsel filed a Fourth Amendment-based motion to suppress evidence from the stop, obtained an evidentiary hearing, was granted leave to file a supporting memorandum but never filed one, and ultimately withdrew the motion before trial.
Defendant was convicted of two counts of possession of a controlled substance and one count of possession of drug paraphernalia; on appeal he argued his trial counsel was ineffective for not pressing the suppression motion (and for failing to seek suppression of alleged un-Mirandized statements).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel’s performance was objectively deficient for withdrawing/not pursuing the suppression motion	State: Counsel made tactical choices and record does not show deficiency; defendant failed to show the Fourth Amendment motion would have succeeded	Lantz: Counsel neglected the case (no memorandum, withdrew motion), and should have moved to suppress his statements separately (Miranda)	Court: No deficiency shown; counsel withdrew motion and defendant did not show the Fourth Amendment motion would have prevailed; issue inadequately briefed regarding Fourth Amendment
Whether any deficient performance prejudiced the defense (reasonable probability of a different outcome)	State: Even without Defendant’s statements, physical evidence and testimony overwhelmingly supported convictions	Lantz: If his statements were excluded, jury could have had reasonable doubt	Court: No prejudice — other strong evidence (ownership, drugs in his vehicle, cash, Driver’s testimony) made a different outcome unlikely

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda rule protects against admission of statements made during custodial interrogation absent warnings)
Strickland v. Washington, 466 U.S. 668 (1984) (two-part test for ineffective assistance: deficient performance and prejudice)
State v. Clark, 89 P.3d 162 (Utah 2004) (courts defer to tactical decisions; prejudice requires reasonable probability of different result)
State v. Mohamud, 395 P.3d 133 (Utah 2017) (prejudice element quoted and applied)
State v. Gerber, 347 P.3d 852 (Utah Ct. App. 2015) (absence of evidence cannot overcome presumption that counsel’s conduct was reasonable)
State v. Lee, 318 P.3d 1164 (Utah Ct. App. 2014) (defendant must produce evidence that would have been available absent counsel’s alleged deficiency)