State v. Reyos, 402 P.3d 113

Background

Late-night fight left a 16-year-old (Victim) shot and abandoned; Reyos was accused of putting a gun to Victim’s head and shooting him in a Sugar House alley.
Sarah (passenger) testified she heard the shot, later resisted Reyos’s effort to suppress her account, and ultimately told police Reyos killed Victim.
John (acquaintance) gave a recorded police statement implicating Reyos and signed a written statement, but at trial claimed no memory of the interview or the conversation with Reyos.
The trial court admitted John’s out-of-court statements under Utah Rule 801 as non-hearsay because John testified and was cross-examined at trial; the jury convicted Reyos of aggravated murder and firearm possession by a restricted person.
Reyos was sentenced to life without parole plus a consecutive term; he appealed, arguing (1) Confrontation Clause violation by admission of John’s statements and (2) multiple constitutional challenges to Utah’s aggravated murder sentencing scheme.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Reyos)	Held
Whether admission of John’s recorded police statements violated the Sixth Amendment Confrontation Clause	Statements admissible because John testified at trial, was subject to cross-examination, and the statements were non-hearsay under Utah R. Evid. 801(d)(1)(A)	John’s claimed total amnesia made him "unavailable" and precluded meaningful cross-examination, so admission violated Confrontation Clause	Court held no violation: declarant testified at trial so Confrontation Clause not triggered; Owens and Crawford permit admission when declarant appears and is cross-examined
Whether Utah’s aggravated murder sentencing scheme violates Due Process under Apprendi/Alleyne by allowing judge (not jury) to impose life without parole	Section 76-3-207.7 does not require judge to make any factfinding that increases statutory maximum or mandatory minimum; judge’s discretion within statutory range is permissible	Imposition of life without parole by judge increases mandatory minimum and thus requires jury findings under Apprendi/Alleyne	Court rejected Reyos’s Apprendi/Alleyne challenge: section 207.7 does not authorize judicial factfinding that increases statutory maxima/minima; judge’s discretionary choice within statutory sentencing options is constitutional
Whether sentencing scheme violates Utah Uniform Operation of Laws Clause or Equal Protection by treating capital and noncapital aggravated murder defendants differently	Different procedures are rational: capital cases (death-eligible) legitimately treated differently; statutes apply uniformly within their classes	Scheme divides similarly situated defendants into subclasses with disparate treatment (jury vs. judge sentencing)	Court upheld scheme: defendants charged under different statutes are not similarly situated; precedent (Perea, Met, Houston) supports constitutionality; no Equal Protection/Uniform Operation violation

Key Cases Cited

Crawford v. Washington, 541 U.S. 36 (landmark Confrontation Clause framework: testimonial statements require unavailability + prior opportunity for cross-examination)
Ohio v. Roberts, 448 U.S. 56 (discussed reliability test superseded by Crawford)
Davis v. Washington, 547 U.S. 813 (distinguishes testimonial vs. nontestimonial police statements)
United States v. Owens, 484 U.S. 554 (witness memory loss, without more, does not violate Confrontation Clause if witness testifies and is cross-examined)
Apprendi v. New Jersey, 530 U.S. 466 (facts increasing penalty beyond prescribed range must be submitted to a jury)
Alleyne v. United States, 570 U.S. 99 (extends Apprendi to facts that increase mandatory minimums)
State v. Met, 388 P.3d 447 (Utah 2016) (upholding distinctions in aggravated murder sentencing scheme)
State v. Houston, 353 P.3d 55 (Utah 2015) (rejecting Apprendi challenge to Utah sentencing statute)
State v. Perea, 322 P.3d 624 (Utah 2013) (upholding section 207.7 against Uniform Operation of Laws challenge)