State v. Lightel
2025 UT App 40
Utah Ct. App.2025Background
- Kadin Woolf Lightel pled guilty to eighteen counts of sexual exploitation of a minor (possession of child pornography) at age twenty.
- Utah law typically requires lifetime sex offender registration for adults convicted of this offense, unless an exception applies.
- The relevant exception applies if the offender was under 21 and the offense did not involve force or coercion.
- The district court, based on a pre-sentence report, found at least some images Lightel possessed depicted force or coercion.
- Lightel argued at sentencing and on appeal that only his conduct (not the content of the images) should be considered for the force/coercion exception.
- The district court declined to find the exception applied and required lifetime registration; Lightel appealed.
Issues
| Issue | Lightel's Argument | State's Argument | Held |
|---|---|---|---|
| Whether the exception to lifetime registration applies if the offender, under 21, did not personally use force/coercion | The court should look only at the offender's actions, not the material's content | The court should consider both the offender's actions and whether the material depicted force/coercion | The statute requires examining both conduct and content; exception does not apply |
| Statutory interpretation of "the offense...does not involve force or coercion" | "Offense" means only the defendant’s acts; content of images irrelevant | "Offense" includes both acts and images possessed; images depicting force/coercion make exception inapplicable | The statutory context supports considering images' content; the exception is unavailable if any material depicts force/coercion |
| Whether force or coercion must be an element of the crime to trigger the exception | Exception applies unless force/coercion is an element of the crime | Exception applies only where neither the acts nor any content involved force/coercion | The legislative intent was to require a two-part inquiry—age and particular offense content—before granting the exception |
| Interpretation of legislative intent behind lifetime registration exception | Exception should be broadly available to age-eligible offenders | Exception is narrowly available, requiring careful factual findings | Context requires narrow interpretation; exception is not automatic for young offenders |
Key Cases Cited
- State v. Bagnes, 322 P.3d 719 (Utah 2014) (dictionary definitions are starting points for plain meaning but context is determinative)
- Olsen v. Eagle Mountain City, 248 P.3d 465 (Utah 2011) (context and statutory scheme guide interpretation, not isolated words)
- Croft v. Morgan County, 496 P.3d 83 (Utah 2021) (statutory language must be given operative effect)