State v. Sanchez
2018 UT 31
Utah2018Background
- Victim was tortured over 7–10 hours by her boyfriend, James Sanchez, and died from combined blunt force injuries and strangulation. Sanchez later admitted many assaults and gave a recorded interview to Detective Chad Reyes.
- At trial, portions of Sanchez’s statements to Detective Reyes—claiming the victim said she was cheating with Sanchez’s brother and refused to promise to stop—were excluded by the trial court; Detective Reyes testified to other parts of the interview.
- Sanchez sought admission of the excluded statements under Utah Rule of Evidence 106 (rule of completeness); the trial court denied the request. Sanchez was convicted of first-degree murder.
- The Utah Court of Appeals held the trial court abused its discretion under rule 106 but deemed the error harmless; Sanchez petitioned for certiorari as to harmlessness and the court of appeals’ extreme-emotional-distress analysis, and the State cross-petitioned on the rule 106 holding.
- The Utah Supreme Court granted certiorari, vacated the court of appeals’ rule 106 and objective-standard holdings, clarified the extreme emotional distress standard, and affirmed the harmlessness determination on alternative grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility under Utah R. Evid. 106 | State: court of appeals erred to allow rule 106 to defeat other evidence rules | Sanchez: excluded portions of his interview should be admitted under rule 106 to complete the admitted statements | Supreme Court vacated the court of appeals’ rule 106 ruling and declined to decide applicability; left question open for future cases |
| Standard for harmless error | State: any evidentiary error was harmless under regular harmless-error review | Sanchez: exclusion was constitutional (right to present a defense) requiring heightened review | Court held regular harmless-error standard applies because Sanchez failed to preserve a constitutional claim |
| Application of extreme emotional distress mitigation (objective prong) | Sanchez: proffered statements would support objective reasonableness for mitigation | State: objective reasonableness lacking given prolonged, calculated conduct | Court vacated court of appeals’ objective-prong analysis (incorrect standard) and clarified proper inquiry (reasonable explanation need only justify the distress, not the killing) |
| Whether excluded statements made harmless difference to mitigation outcome | Sanchez: admission likely would have led jury to find special mitigation (manslaughter) | State: even with proffered statements, no reasonable likelihood jury would find subjective extreme emotional distress contemporaneous with killing | Court held any error was harmless—no reasonable likelihood jury would have found Sanchez subjectively under extreme emotional distress at time of death |
Key Cases Cited
- State v. Thomas, 974 P.2d 269 (1999) (harmless-error standard described)
- State v. White, 251 P.3d 820 (2011) (objective-reasonableness inquiry for extreme emotional distress)
- State v. Bishop, 753 P.2d 439 (Utah 1988) (defining extreme emotional distress elements)
- State v. Colwell, 994 P.2d 177 (2000) (test for harmlessness when evidence wrongly excluded)
- State v. Dean, 95 P.3d 276 (2004) (preservation requirement for appellate review)
- Ross v. State, 293 P.3d 345 (2012) (discussion of predecessor extreme emotional distress doctrine)