State v. Nelson, 355 P.3d 1031

Nelson shot and killed two men, Grijalva and Davis, eight times each, including a fatal headshot, and buried their bodies in a shallow grave covered with trash and waste.
After murders, Nelson disposed of evidence in trailers, a truck, and the scene, including removing carpet, repainting floors, and dismantling a truck.
Nelson claimed self-defense at trial; the jury convicted him of two counts of aggravated murder and a theft by receiving a stolen vehicle.
Investigators later executed warrants, performed a protective sweep, and discovered the victims’ bodies; evidentiary suppression issues arose over the warrantless discovery and later search warrants.
Nelson raised seven IAC claims on appeal (six from a Rule 23B hearing and one new on appeal); the district court denied these, and the Utah Supreme Court affirms, finding no deficient performance or prejudice.
Standard of review and governing law (Strickland two-part test) applied; district court findings given deference where factual; seventh claim evaluated as law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel erred in presenting a reenactment of the shooting	Nelson contends reenactment was improper and prejudicial	Counsel reasonably used reenactment as strategic to align theory with evidence	Not deficient; strategic trial decision, no prejudice shown
Whether introducing probation evidence was objectively unreasonable	Probation status would prejudice jury	Probation explanation plausible to contextualize conduct	Not deficient; permissible strategic justification, no prejudice
Whether counsel should have impeached officers about truck discovery	Officers lied about truck discovery timing	Impeachment would not yield probative value; timing not central to defense	Not deficient; impeachment would not affect outcome
Whether failure to present certain blood evidence in the trailer was prejudicial	Non-negative field test could corroborate self-defense	Evidence would be tenuous and not affect outcome	Not prejudicial; no reasonable probability of different result
Whether voir dire and jury instructions were improperly handled	Procedural defects in voir dire and roadmap instruction	Totality of instructions fairly guided deliberations	Not prejudicial; instructions viewed as a whole supported verdict

Strickland v. Washington, 466 U.S. 668 (1984) (two-part test for ineffective assistance of counsel)
Menzies v. State, 2014 UT 40 (Utah 2014) (requires showing prejudice with substantial likelihood of different outcome)
State v. Clark, 2004 UT 25 (Utah 2004) (strong presumption of adequacy; wide latitude for trial strategy)
State v. Chacon, 962 P.2d 48 (Utah 1998) (prejudice standard; show reasonable probability of different result)
State v. Wright, 2013 UT App 142 (Utah App. 2013) (defers to district court findings of fact; legal conclusions reviewed for correctness)
State v. Hutchings, 2012 UT 50 (Utah 2012) (prejudice analysis for jury instruction issues; totality of evidence)
State v. Brooks, 638 P.2d 537 (Utah 1981) (instructions must be read as a whole; not reversible for minor imperfections)
United States v. Rolle, 204 F.3d 133 (4th Cir. 2000) (voir dire practice; use of questionnaires common in jury selection)
Jensen v. Intermountain Power Agency, 1999 UT 10 (Utah 1999) (briefing standards; adequate briefing required for IAC claims)
State v. Geukgeuzian, 2004 UT 16, 86 P.3d 742 (Utah 2004) (standard for reviewing suppressions and evidentiary issues)