State v. Mackin, 283 P.3d 997

Mackin was convicted on three counts following a 2008 jury trial, where he represented himself.
He challenged the State’s failure to disclose or preserve video/audio tapes from the traffic stop and arrest.
A handwritten mistrial motion alleging destruction of evidence was not ruled on before sentencing.
Mackin filed posttrial motions for a new trial based on Brady violations; district court denied these motions in January 2011.
Mackin filed an August 2008 notice of appeal; this court later determined jurisdiction was limited and dismissed the appeal for lack of jurisdiction to review the new-trial denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction to review new-trial denial	Mackin argues the district court erred in denying his rule 24 motion and seeks review of that ruling.	State contends this court lacks jurisdiction to review the district court’s denial of the new-trial motion.	Lack of jurisdiction; cannot review the new-trial denial.
Scope of appellate review after an earlier notice of appeal	Mackin's arguments relate to the denial of the new trial, not the underlying conviction.	State maintains arguments address only the postconviction denial, not the conviction itself.	Appeal limited to underlying conviction; posttrial denial not reviewable here.

State v. Ingleby, 2004 UT App 447 (Utah Court of Appeals 2004) (premature notices of appeal become timely from sentencing)
State v. Reyes, 2002 UT 13 (Utah Supreme Court 2002) (dismisses appeal when only issue concerns denials on postconviction motions)