State v. Maughan, 2013 UT 37

In 1984 Brad Perry was murdered; years later investigators linked Glenn Griffin to the crime and pursued witness Wade Maughan, who confessed to assisting Griffin.
The State prosecuted Griffin first and granted Maughan use immunity to compel his testimony against Griffin.
Maughan refused to testify despite court orders warning of contempt and prosecution; the State charged him with obstruction of justice under Utah Code § 76-8-306(1).
At the preliminary hearing the magistrate found no evidence of the specific intent required for obstruction (intent to hinder, delay, or prevent prosecution) and dismissed the charges.
The Utah Court of Appeals affirmed, finding the record supported only the inference that Maughan acted to protect himself, not to hinder Griffin’s prosecution.
The Utah Supreme Court granted certiorari and reversed, holding the State presented sufficient evidence to bind Maughan over for trial because the bindover standard requires drawing all reasonable inferences for the prosecution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient at preliminary hearing to bind over Maughan for obstruction of justice (specific intent to hinder prosecution)	State: evidence of friendship, prior confession, and refusal to testify after immunity supports a reasonable inference Maughan intended to hinder Griffin’s prosecution	Maughan: his repeated distrust of immunity and desire to protect himself from prosecution shows intent was to preserve his own rights, not to hinder Griffin	The Court reversed: evidence could reasonably support a jury finding of intent to hinder; bindover required, and magistrate should draw reasonable inferences for prosecution rather than choose the most plausible inference.
Whether the court of appeals improperly reweighed evidence at bindover	State: appellate court improperly substituted its view of the most reasonable inference for the permissive bindover standard	Maughan: appellate court correctly concluded the totality of evidence supported only self-protective intent	Held: appellate court erred—bindover standard is lenient and does not allow rejecting a reasonable prosecution inference simply because another inference is more plausible.

State v. Ramirez, 289 P.3d 444 (Utah 2012) (describes de novo review and bindover standard principles)
State v. Clark, 20 P.3d 300 (Utah 2001) (prosecution must produce believable evidence of every element to bind over)
State v. Smith, 728 P.2d 1014 (Utah 1986) (motive and circumstantial evidence can establish intent)
State v. James, 819 P.2d 781 (Utah 1991) (intent generally proven circumstantially)
State v. Maughan, 276 P.3d 1258 (Utah Ct. App. 2012) (court of appeals decision affirming magistrate that the Supreme Court reversed)