State v. Rivera, 385 P.3d 685

Rivera, while on probation, obtained her coworker Victim’s personal/financial information and opened multiple credit cards in Victim’s name, using them for purchases and bragging about it.
Victim discovered the fraud after collection notices; police investigation led to charges of identity fraud and forgery.
Rivera, diagnosed with bipolar disorder and found competent to stand trial, pled "guilty with a mental illness" to one forgery and three identity-fraud third-degree felonies as part of a global resolution.
At sentencing the court ordered a presentence investigation report (PSI); defense counsel sought a 10-day continuance claiming late delivery of the PSI under the statutory three-working-day rule. The court denied the continuance but gave 90 extra minutes for corrections. Rivera presented corrections and victim-impact testimony.
The court sentenced Rivera to concurrent terms of 0–5 years on each count (declining consecutive terms) and relied on prison mental-health services for treatment. Rivera later filed additional PSI corrections and moved to correct sentence under section 77-16a-104; the motion was denied. She appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion by denying 10-day continuance to review PSI	Rivera: statutory three-working-day PSI delivery entitled her to additional time and continuance to prepare objections	State: trial court has discretion over continuances; any PSI delivery failures are department's duty and not mandatory relief	Court: No reversible abuse; even if discretion exercised, Rivera showed no prejudice because she presented objections at sentencing and later submitted corrections to Board of Pardons
Whether prison sentence was excessive	Rivera: court failed to consider legally relevant factors and imposed excessive sentence	State: sentencing was within court’s discretion given victim harm balanced against mental illness	Court: Claim inadequately briefed—appellant offered only conclusory assertions and failed to support with record; issue not adjudicated on merits
Whether Rivera was entitled to a formal mental-health hearing under § 77-16a-103	Rivera: trial court should have held a § 77-16a-103 hearing regarding her mental illness at sentencing	State: trial court considered and applied § 77-16a-104 (procedure following guilty-with-mental-illness finding) as urged by Rivera below	Court: Argument barred by invited-error doctrine—Rivera urged the court to apply § 77-16a-104 and cannot now complain that a different provision should have been used

State v. Madsen, 57 P.3d 1134 (Utah Ct. App. 2002) (interpreting that the PSI delivery requirement is directed to the department and does not limit trial-court discretion)
State v. Abelon, 369 P.3d 113 (Utah Ct. App. 2016) (harmlessness and effect of unaddressed PSI objections on review)
State v. Monroe, 345 P.3d 755 (Utah Ct. App. 2015) (remand for PSI corrections not required where report was already forwarded)
Van Cott v. Wall, 178 P. 42 (Utah 1918) (invited-error principle: a party cannot complain on appeal about an error it induced)