State v. Martinez, 304 P.3d 110

In Jan 2010, Martinez arranged a drug sale at a public park; during the transaction he stabbed Luis Torres after Torres threatened him with a gun.
Martinez was charged and convicted by a jury of aggravated assault (third-degree felony) and arranging to distribute a controlled substance in a drug-free zone (second-degree felony).
At trial Martinez asserted self-defense; the court instructed the jury on self-defense but did not separately explain the parties’ relative burdens of proof regarding that defense.
Martinez did not object to the jury instructions below and therefore raises the instructional error on appeal under the plain-error standard.
He also argues ineffective assistance of counsel for failing to request a burdens-of-proof instruction on self-defense.
The State argued, and the court agreed, that self-defense is unavailable because the stabbing occurred during the attempted commission of a felony (the drug transaction).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Martinez)	Held
Whether the trial court’s self-defense instructions were erroneous for failing to explain burdens of proof	Instructions were adequate; even if imperfect, any error was not harmful because self-defense is unavailable when force is used during commission of a felony	Failure to instruct on burdens deprived jury of necessary guidance on self-defense, requiring reversal	No reversible error: any instructional omission was not harmful because self-defense was statutorily precluded by the felony drug transaction
Whether Martinez received ineffective assistance of counsel for not requesting a burdens-of-proof instruction	Counsel’s conduct did not prejudice Martinez because, given the statutory bar, proper instructions would not have produced a different result	Counsel’s omission was objectively unreasonable and prejudiced the defense because proper instructions likely would have created reasonable doubt	No ineffective assistance: Martinez cannot show a reasonable probability of a different outcome because self-defense was unavailable under the statute

Burk v. State, 839 P.2d 880 (Utah Ct. App. 1992) (standard of reciting facts in light most favorable to verdict)
Lucero v. State, 283 P.3d 967 (Utah Ct. App. 2012) (self-defense instruction required when evidence gives reasonable basis for it)
Knoll v. State, 712 P.2d 211 (Utah 1985) (self-defense instruction principles)
Lee v. State, 128 P.3d 1179 (Utah 2006) (plain-error review and manifest injustice standard)
Powell v. State, 154 P.3d 788 (Utah 2007) (plain-error and ineffective-assistance standards explained)
Dunn v. State, 850 P.2d 1201 (Utah 1993) (plain-error three-prong test)
Strickland v. Washington, 466 U.S. 668 (1984) (ineffective-assistance two-pronged test)
Jimenez v. State, 284 P.3d 640 (Utah 2012) (lack of prejudice is dispositive for plain-error claims)