State v. Maama, 359 P.3d 1266

On March 30, 2012, Semisi Maama, his sister Mesia, Mesia’s boyfriend Pham, and a friend were in a fast-food parking lot; Pham pointed a gun at a father and demanded money while Maama stood next to him.
The father’s son gave Pham $11–$12; the father then grabbed the gun from Pham and a physical struggle ensued; the father briefly disarmed the robbers.
Mesia exited the restaurant, told the group to leave, then re‑engaged to recover the gun; Mesia retook the gun and the group fled in a vehicle.
Maama was convicted of aggravated robbery (1st degree felony), riot (3rd degree felony), and misdemeanor assault; he appealed, challenging jury instructions and the trial judge’s neutrality/intervention.
The crux of the appeal: (1) whether the jury instruction on the compulsion affirmative defense properly conveyed the State’s burden to disprove compulsion beyond a reasonable doubt; (2) whether the judge’s facial expressions and a sua sponte interjection required a mistrial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adequacy of compulsion instruction	State: either compulsion not warranted or instruction given was sufficient	Maama: instruction failed to tell jury State must disprove compulsion beyond reasonable doubt	Court: Maama was not entitled to compulsion instruction on facts; Instruction 61 adequately stated the State’s burden
Judicial demeanor (facial expressions)	State: claim not preserved; no prejudice shown	Maama: judge’s eye‑rolling prejudiced jury requiring mistrial	Court: issue not preserved at trial; appellate review declined
Sua sponte interjection correcting witness	State: curative instruction sufficed	Maama: interjection showed bias and aided prosecution; mistrial required	Court: defendant requested mistrial or alternative curative instruction; judge gave curative instruction and no unacceptable prejudice shown; no abuse of discretion

State v. Tuttle, 730 P.2d 630 (Utah 1986) (defines compulsion as requiring a specific threat and no reasonable alternative)
State v. Low, 192 P.3d 867 (Utah 2008) (State must disprove an affirmative defense beyond a reasonable doubt once defense is put in issue)
State v. Menzies, 889 P.2d 393 (Utah 1994) (trial court need not grant mistrial when requested alternative relief is given unless unacceptable prejudice shown)
State v. Marchet, 219 P.3d 75 (Utah Ct. App. 2009) (jury instructions need not follow a particular form so long as they accurately convey the law)
State v. Kruger, 6 P.3d 1116 (Utah 2000) (on appellate review, view evidence in light most favorable to the verdict)