State v. Sanchez, 380 P.3d 375

Sanchez admitted in a recorded police interview that he assaulted and strangled his girlfriend after a prolonged attack; the victim had extensive bruising, fractures, and signs of strangulation.
The State introduced the recorded interview (confession) via the detective; Sanchez sought to admit a separate portion of the interview in which he said the victim repeatedly told him she was cheating with his brother (his proffered explanation for the assault).
The trial court excluded that explanatory portion under Rule 106, ruling it was self-serving, temporally remote, and inadmissible hearsay (double hearsay). Sanchez did not testify at trial.
Sanchez was convicted of first-degree murder and second-degree obstruction of justice; he appealed, arguing (1) Rule 106 required admission of the explanatory statement and (2) insufficient evidence supported the obstruction conviction.
The appellate court held (a) Rule 106 permits admitting otherwise inadmissible hearsay when fairness requires it and the trial court abused its discretion by excluding Sanchez’s explanatory statement, but the error was harmless as to special mitigation; and (b) the obstruction-of-justice conviction was supported by sufficient evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Utah R. Evid. 106 required admission of a portion of Sanchez’s recorded statement that explained his motive for the assault	Sanchez: The explanatory portion was necessary to qualify, explain, and place the prosecution’s introduced confession in context under Rule 106, and the victim’s repeated statements were offered only to show they were made (not for their truth)	State: The explanatory portion was temporally remote, self-serving, and inadmissible hearsay (double hearsay); Rule 106 does not override hearsay rules	Court: Rule 106 can require admission of otherwise inadmissible hearsay when fairness demands; trial court abused discretion by excluding the statement, but the error was harmless as it would not likely have led to special mitigation success
Whether evidence was sufficient to support obstruction of justice conviction	Sanchez: Although he cleaned the scene, there was no evidence he did so after the victim died or with intent specifically to hinder investigation of her murder	State: The statute requires intent to hinder investigation of criminal conduct generally, not identity between concealed acts and the eventual crime charged	Court: Sufficient evidence supported obstruction conviction; statute requires intent to hinder investigation of criminal conduct broadly, not identity with final charge

State v. Jones, 345 P.3d 1195 (Utah 2015) (describes Rule 106 fairness purpose and framework)
State v. Colwell, 994 P.2d 177 (Utah 2000) (harmless-error standard when evidence should have been admitted)
State v. Leleae, 993 P.2d 232 (Utah Ct. App. 1999) (circumstances where excluded self-serving statement did not require admission under Rule 106)
United States v. Sutton, 801 F.2d 1346 (D.C. Cir. 1986) (Rule 106 interpreted to permit admitting otherwise inadmissible material for fairness)
United States v. Lopez-Medina, 596 F.3d 716 (10th Cir. 2010) (factors for fairness and contextual admission under Rule 106)
United States v. Harry, 816 F.3d 1268 (10th Cir. 2016) (Rule 106 can override hearsay exclusion when fairness requires)
Beech Aircraft Corp. v. Rainey, 488 U.S. 153 (1988) (discusses completeness doctrine and admission of truncated materials)
State v. Drej, 233 P.3d 476 (Utah 2010) (upholding statutory allocation of burden for special mitigation)
State v. White, 251 P.3d 820 (Utah 2011) (defines objective/subjective standards for extreme emotional distress special mitigation)