State v. Logue, 436 P.3d 136

In May 2011 Victim (a suspected informant) was found shot in his driveway and later died; police linked the killing to retaliation for information given to officers after a prior search of a drug dealer’s storage unit.
Yuri Lara arranged to have Victim assaulted for allegedly informing; Lara recruited Morris, who then enlisted Logue (both gang members). Logue brought a gun to Victim’s house and shot Victim when Victim attempted to make a call.
Key testimonial evidence: Girlfriend testified Logue asked her to buy ammunition the day before the murder and that Logue admitted shooting Victim; Friend and Customer provided statements implicating Logue and Morris; no murder weapon or decisive forensic evidence was recovered.
The State charged Logue with aggravated murder (alleging several aggravators including preventing testimony/retaliation), possession of a firearm by a restricted person, and obstruction of justice; the jury convicted on all counts.
At trial the State introduced a midtrial-obtained Walmart receipt for ammunition; defense argued late disclosure and moved for exclusion/new trial. The court admitted the receipt and denied relief.
Logue appealed challenging sufficiency of evidence for aggravators, admission of the Walmart receipt as unfairly prejudicial, and the constitutionality of Utah’s aggravated-murder sentencing scheme; the Court of Appeals affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Logue)	Held
Sufficiency of evidence for murder intent and aggravators	Evidence (gun brought to scene, eyewitness confessions, circumstantial facts) supports intent to kill and that killing was to prevent/testimony or retaliate	Evidence shows only intent to assault; not enough proof of intent to kill or that murder was to prevent testimony/retaliation	Affirmed: sufficient evidence to infer murder intent and at least one aggravator (preventing testimony/retaliation)
Admission of Walmart receipt	Receipt corroborates Girlfriend’s testimony about ammunition purchase; probative and admissible	Receipt was disclosed late, undermined defense counsel’s opening statement and prejudiced Logue; warrants exclusion or new trial	Affirmed: trial court did not abuse discretion; receipt’s probative value not substantially outweighed by unfair prejudice
Denial of directed verdict	N/A (State opposed directed verdict)	Directed verdict should have been granted for insufficient evidence on aggravated murder	Affirmed denial: reasonable jury could find elements beyond reasonable doubt
Constitutionality of sentencing scheme (Utah Code §§ 76-5-202 and 76-3-207.7)	Statute valid; sentencing scheme previously upheld	Scheme violates equal protection, due process, uniform operation clause, and jury trial rights because prosecutor’s choice alters sentencing path	Affirmed: scheme constitutional (controlling precedent resolves challenge)

State v. Boyd, 25 P.3d 985 (Utah 2001) (standard for viewing evidence in support of jury verdict)
State v. Montoya, 84 P.3d 1183 (Utah 2004) (standard for reviewing directed verdict on sufficiency of evidence)
State v. Holgate, 10 P.3d 346 (Utah 2000) (circumstantial evidence and proving intent)
State v. Dunn, 850 P.2d 1201 (Utah 1993) (presumption in favor of admissibility and Rule 403 analysis)
Met v. State, 388 P.3d 447 (Utah 2016) (upholding constitutionality of Utah’s dual-track aggravated-murder sentencing scheme)