State v. Sisneros, 464 P.3d 180

In August 2017 Sisneros test-drove a car in North Ogden (Weber County) with the seller’s father present; after the drive he jumped back into the running car and drove off while Father attempted to stop him and was bumped.
Sisneros drove the car ~70 miles to Utah County; a friend recognized the car from the owner’s social-media post and police recovered the abandoned vehicle and the keys where Sisneros said he discarded them.
Utah County charged Sisneros with theft by receiving stolen property and obstruction (Aug 16); the probable cause statement recounted his confession that he took the car from Father.
Weber County later charged Sisneros with aggravated robbery based on taking the car from Father by force/fear (Aug 22). Sisneros pled guilty in Utah County to theft by receiving and obstruction (Aug 31).
Sisneros moved in Weber County to dismiss the aggravated-robbery charge under Utah Code § 76-1-403 (single criminal episode / claim preclusion); the district court denied the motion, he entered a conditional guilty plea reserving appeal.
The Court of Appeals held the theft and aggravated robbery arose from a single criminal episode, were within the jurisdiction of a single court, the Utah County prosecutor knew of the robbery-related conduct at arraignment, and the prior conviction barred the subsequent prosecution — vacating the aggravated robbery conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 76-1-403 barred Weber County’s aggravated robbery prosecution because Sisneros had already been prosecuted and convicted in Utah County for theft by receiving arising from the same criminal episode	The offenses were distinct and sequential: aggravated robbery occurred in Weber County (force on Father) while theft by receiving occurred later in Utah County (retention/possession from the owner); different victims and separate criminal episodes.	The robbery and theft by receiving occurred essentially simultaneously when Sisneros took the car; both advanced the single objective of unlawfully obtaining the car; the Utah County prosecutor had notice of robbery-related conduct at the first arraignment; both offenses could be tried in the same court; prior conviction therefore bars subsequent prosecution.	The court vacated the aggravated robbery conviction: the offenses arose from a single criminal episode, were within the jurisdiction of a single court, the first prosecutor knew of the later charge’s underlying conduct at arraignment, and the prior conviction barred the subsequent prosecution under § 76-1-403.

State v. Ririe, 345 P.3d 1261 (2015 UT 37) (describing § 76-1-403 single criminal episode / one-bite-at-the-apple rule)
State v. Selzer, 294 P.3d 617 (2013 UT App 3) (statutory purpose: protect against successive prosecutions and promote finality)
State v. Rushton, 395 P.3d 92 (2017 UT 21) (factors for single criminal objective analysis)
Salt Lake City v. Josephson, 435 P.3d 255 (2019 UT 6) (prosecutor’s knowledge at first arraignment controls § 76-1-402(2)(b) inquiry)
State v. Ireland, 570 P.2d 1206 (Utah 1977) (distinguishable precedent where temporally separated crimes were not a single episode)