455 P.3d 1093
Utah Ct. App.2019Background
- Peterson, a daily meth user, killed his mother and brother on a Utah farm; he later admitted the killings and told officers he used meth and experienced hallucinations that made him believe they were demons.
- Before the killings he told family members an "entity" had told him to kill Brother and expressed intent to kill Brother; after shooting Mother he reloaded and shot Brother at point-blank range, then took money from Brother and fled.
- Peterson called 911 beforehand claiming he felt his life was in danger; officers removed weapons, spoke with him, and later encountered signs of paranoia but not clear intoxication.
- At trial Peterson asserted a voluntary-intoxication (methamphetamine psychosis) defense, arguing he lacked the mens rea for aggravated murder and could only be guilty of manslaughter.
- The jury convicted Peterson of manslaughter for Mother but aggravated murder for Brother; Peterson moved to arrest judgment as inconsistent, arguing the jury accepted his intoxication defense for one killing but not the other.
- The district court denied the motion; the Court of Appeals affirmed, holding sufficient evidence supported a finding that Peterson intentionally/knowingly killed Brother.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the aggravated-murder verdict for killing Brother must be arrested as inconsistent with the manslaughter verdict for killing Mother given Peterson's voluntary-intoxication defense | The State: sufficient evidence supports aggravated murder for Brother; inconsistent verdicts alone do not require reversal | Peterson: jury accepted voluntary-intoxication defense for Mother but not Brother despite the killings' close temporal proximity, so verdicts are internally inconsistent and conviction should be arrested | Affirmed: assuming arguendo inconsistency, sufficient evidence (prior threats, reloading, point-blank shooting, theft from Brother, flight/admission) supports intent/knowledge to kill Brother, so denial of arrest judgment was proper |
Key Cases Cited
- State v. LoPrinzi, 338 P.3d 253 (Utah Ct. App. 2014) (standard for reviewing alleged inconsistent jury verdicts)
- State v. Cady, 414 P.3d 974 (Utah Ct. App. 2018) (courts uphold each guilty verdict if sufficient evidence supports it despite apparent inconsistency)
- Honie v. State, 342 P.3d 182 (Utah 2014) (voluntary intoxication may negate mens rea but must be supported by evidence)
- State v. Montoya, 84 P.3d 1183 (Utah 2004) (some evidence of intent is sufficient to sustain conviction)
- Neff v. Neff, 247 P.3d 380 (Utah 2011) (resolve internal jury inconsistencies in favor of giving effect to the verdict)