State v. Maughan
276 P.3d 1258
| Utah Ct. App. | 2012Background
- Maughan was granted use immunity to compel his testimony at Griffin's capital murder trial.
- Maughan initially gave a lengthy statement to police implicating Griffin but later refused to answer questions
- Griffin was tried and convicted without Maughan's testimony; Maughan was later charged with obstruction of justice for refusing to cooperate
- Magistrate at the preliminary hearing found no evidence that Maughan acted with the specific intent to hinder Griffin's prosecution
- Appellate court applied a totality-of-the-evidence approach and held the total evidence supported only a self-protective, not hindering, inference
- Court affirmed the magistrate’s bindover denial and dismissed the obstruction charge against Maughan
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether probable cause supported binding over for obstruction of justice | Maughan's refusals, under immunity, showed intent to hinder Griffin | Maughan acted to protect his own rights, not to hinder Griffin | No; evidence supports self-protection inference, not specific hindrance |
| Whether the magistrate properly weighed inferences about specific intent | The evidence supports an inference of intent to hinder due to immunity context and refusals | Total evidence favors self-protection inference | Total evidence favors self-protection; hindering inference is speculative |
| Whether the standard of review and bindover framework were correctly applied | State applied correct standard to infer intent | Magistrate must not infer more than reasonable belief; cannot speculate | The magistrate's declination to bind over was correct under proper standard |
Key Cases Cited
- State v. Virgin, 137 P.3d 787 (Utah 2006) (probable-cause standard for bindover; need reasonable belief)
- State v. Clark, 20 P.3d 300 (Utah 2001) (probable-cause standard; light burden at preliminary hearing; view evidence in prosecutorial light)
- In re I.R.C., 232 P.3d 1040 (Utah 2010) (totality-of-the-evidence approach to inference at bindover)
- State v. Hester, 3 P.3d 725 (Utah Ct. App. 2000) (inferencing from facts; avoid weighing evidence at preliminary stage)
- State v. Cristobal, 238 P.3d 1096 (Utah Ct. App. 2010) (reasonable-inference standard; avoid speculative inferences)