State v. Main, 494 P.3d 1056

James Main shot and killed his father at a remote cabin and then fled to his friend D.N.’s home, where he threatened occupants, took clothing and electronics, and struggled over a gun. Police later found Main and multiple blood-stained items belonging to him in D.N.’s house and vehicles.
Main was charged with murder and multiple related offenses; the aggravated murder charge was reduced to murder and eleven other charges were bifurcated for separate proceedings.
At trial the defense argued D.N. was the true perpetrator based on the presence of incriminating items at D.N.’s places and D.N.’s statement to police, prompting the court to reconsider admission of evidence tied to the bifurcated charges.
The district court allowed testimony about the linked events as inextricably intertwined (not 404(b) extrinsic acts), concluding the probative value outweighed prejudice under Rule 403 and offering a limiting instruction.
The defense attempted to admit D.N.’s phone records showing three data transmissions; the court excluded them for lack of foundation as to what the transmissions meant/relevance.
Two color crime-scene photographs were contested; defense ultimately introduced one (invited error), and the court admitted the other (35‑B) as probative of where the victim was shot and not unfairly prejudicial. The jury convicted Main of murder; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of evidence related to bifurcated charges (Utah R. Evid. 404(b) and 403)	Evidence was inextricably intertwined with the charged murder (part of the res gestae), highly probative to explain why incriminating items were found with D.N., and not unduly prejudicial.	Evidence was other-crimes evidence barred by Rule 404(b) and unfairly prejudicial under Rule 403.	Court: No abuse of discretion — evidence was inextricably intertwined (or admissible under 404(b) for proper noncharacter purpose), and probative value outweighed unfair prejudice.
Exclusion of D.N.’s phone records (foundation/relevance)	Records either fit a hearsay exception or otherwise were relevant to impeach D.N.’s testimony about no activity.	Records lacked foundation; no witness or expert explained what the data transmissions represented, so relevance and meaning were not established.	Court: Exclusion affirmed — no foundation showing transmissions meant manual phone use, so records were irrelevant for impeachment without explanatory testimony.
Admission of crime-scene photographs (Rule 403; gruesomeness)	Photographs were probative of where the victim was shot and whether the body was moved; probative value outweighed prejudice.	Photographs were gruesome and unfairly prejudicial.	Court: 35‑A admission was invited error by defense; 35‑B admissible — not gruesome, probative re location of gunshot, and not unfairly prejudicial.

State v. Lucero, 328 P.3d 841 (Utah 2014) (inextricably intertwined doctrine and limits of Rule 404(b)).
State v. Thornton, 391 P.3d 1016 (Utah 2017) (discussion of interplay between single criminal episode and inextricably intertwined analysis).
State v. High, 282 P.3d 1046 (Utah Ct. App. 2012) (Rule 404(b) admissibility factors: proper purpose, relevance, Rule 403 balancing).
Met v. State, 388 P.3d 447 (Utah 2016) (Rule 403 balancing test for photographs and other evidence).
State v. Winfield, 128 P.3d 1171 (Utah 2006) (invited error doctrine precluding appellate review when counsel affirmatively waives objection).
State v. Maurer, 770 P.2d 981 (Utah 1989) (definition of unfair prejudice under Rule 403).