464 P.3d 1192
Utah Ct. App.2020Background
- Jason Thomas Law was admitted to a hospital for suicidal ideation and told he would be transferred to another facility; he said he would kill himself rather than be transferred.
- An on-duty police officer in uniform (with a holstered sidearm), two security guards, a technician, a nurse, and Law’s father were present when staff sought to restrain Law and administer a sedative.
- During a scuffle after Law fell from the bed, witnesses testified Law grabbed and forcibly pulled on the officer’s holstered firearm; Officer’s audio recording captured an exchange where Law said, “I’m trying to take my life, not yours.”
- Law was charged with disarming a peace officer (attempted taking of a firearm) and disorderly conduct; a jury convicted on both counts.
- At trial Law moved for a directed verdict arguing insufficient evidence of the required intentional mens rea; the motion was denied and Law appealed the sufficiency ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to prove intentional mens rea for disarming a peace officer | Testimony that Law grabbed and pulled Officer’s holstered gun plus contemporaneous statement that he was trying to take his life support an inference of a conscious objective to take the firearm | No proof Law had a conscious objective to take the weapon; could be jostling or struggle, not intentional disarming | Affirmed — some evidence supported a reasonable jury finding intentional attempt beyond a reasonable doubt |
| Whether an “equally reasonable” alternative inference requires reversal | Ashcraft: an equally plausible innocent inference does not require reversal if the jury’s inference is sustainable | Law: evidence supports an equally reasonable innocent explanation (accidental contact) | Held for State — Ashcraft controls; equally plausible alternatives do not mandate reversal on sufficiency review |
| Robbins (inherent improbability) challenge to Technician’s testimony | Other witness testimony and audio corroborate the essential facts; Robbins exception inapplicable | Technician’s testimony was inconsistent, possibly false, and lacked corroboration so should be disregarded | Not preserved at trial; on plain-error review, Court found no obvious/fundamental insufficiency and corroboration defeated Robbins claim |
| Credibility conflicts between witnesses and audio recording | Jury is the factfinder; contradictions alone do not overturn verdict | Inconsistencies between witnesses and the recording undermine reliability of State’s case | Held for State — appellate court defers to jury credibility determinations; contradictions insufficient to disturb verdict |
Key Cases Cited
- State v. Ashcraft, 349 P.3d 664 (Utah 2015) (equally plausible alternative inference does not require reversal on sufficiency review)
- State v. Gonzalez, 345 P.3d 1168 (Utah 2015) (standard of review for directed verdict/sufficiency challenges)
- State v. Mackin, 387 P.3d 986 (Utah 2016) (affirming jury verdict even where evidence permits multiple reasonable interpretations)
- State v. Cristobal, 238 P.3d 1096 (Utah App. 2010) (earlier articulation about equally plausible inferences, superseded by Ashcraft)
- State v. Robbins, 210 P.3d 288 (Utah 2009) (inherent improbability test for disregarding witness testimony)
- State v. Prater, 392 P.3d 398 (Utah 2017) (clarifies Robbins; corroboration ordinarily defeats inherent improbability claim)