State v. Ririe, 2015 UT 37

In Nov. 2011 a police officer stopped Bobbie Jo Ririe, observed an open beer can, and administered an intoxilyzer; the officer issued at least an open-container citation (disposition facts about a DUI citation are disputed but immaterial).
The officer filed the open-container citation in justice court; Ririe failed to appear and later paid the justice-court fine online, which by statute constituted a forfeiture of bail and entry of conviction.
Separately, prosecutors filed an information in Third District Court charging Ririe with DUI, an alcohol-restricted-driver offense, and open container; the open-container count was later dismissed as barred by double jeopardy after the justice-court conviction.
Ririe moved to dismiss the remaining district-court charges, arguing (1) double jeopardy barred the open-container prosecution (conceded by the State) and (2) Utah Code § 76-1-403 (single criminal episode/claim preclusion) barred the DUI and restricted-driver charges.
The district court denied dismissal of the DUI and restricted-driver charges, reasoning the justice-court disposition did not involve a prosecuting attorney nor an arraignment on an information/indictment as required by §§ 76-1-402(2) and 76-1-403.
The Utah Supreme Court affirmed: § 76-1-403’s preclusive effect is limited to prosecutions where a prosecuting attorney was involved and the defendant was arraigned on an information or indictment; neither element existed here.

Issue	Ririe's Argument	State's Argument	Held
Whether § 76-1-403 bars subsequent prosecution for offenses arising from the same criminal episode when the prior disposition was a justice-court conviction by bail forfeiture	§ 76-1-403 bars the DUI and restricted-driver prosecutions because the prior conviction arose from the same criminal episode	§ 76-1-403 does not apply because the justice-court disposition involved no prosecuting attorney and no arraignment on an information/indictment	Held: § 76-1-403 does not apply; preclusion requires a prior prosecution involving a prosecuting attorney and an arraignment on an information or indictment
Whether the justice-court conviction barred reprosecution of the same open-container offense under double jeopardy	Ririe: double jeopardy bars reprosecution of the open-container offense	State conceded double jeopardy barred reprosecution of the same open-container offense	Held: Open-container count dismissed as double jeopardy barred (conceded by State)

State v. Arave, 2011 UT 84, 268 P.3d 163 (standard of review for motion to dismiss)
State v. Prion, 2012 UT 15, 274 P.3d 919 (double jeopardy protects against multiple prosecutions for same offense)
State v. Sommerville, 2013 UT App 40, 297 P.3d 665 (statutory single‑criminal‑episode preclusion applies to formal prosecutions initiated by filing an information)
VCS, Inc. v. Utah Cmty. Bank, 2012 UT 89, 293 P.3d 290 (statutory text reflects legislative balancing of policies)
McArthur v. State Farm Mut. Auto. Ins. Co., 2012 UT 22, 274 P.3d 981 (statutory enactments balance competing policy considerations)
Hughes Gen. Contractors, Inc. v. Labor Comm’n, 2014 UT 3, 322 P.3d 712 (courts must construe statutory language; may not extend text to achieve perceived policy goals)