State v. Smith, 293 P.3d 1148

Defendant Brian Avery Smith was convicted of possession of a controlled substance (third‑degree felony) and possession of drug paraphernalia (class B misdemeanor) in Utah.
Defendant moved to suppress evidence; trial court refused to consider the motion as untimely under Rule 12(c)(1)(B).
Pretrial proceedings included multiple continuances and scheduling conferences; the suppression motion was filed January 8, 2010.
The court ultimately held a March 2010 trial; the record shows police observations via security camera and ensuing stop/search based on those observations.
On appeal, the State argued the suppression issue was harmless error; Defendant challenged the chain‑of‑custody and authentication of crack pipe and cocaine, and related lab report.
The majority held the motion to suppress was timely interpreted as applicable to the actual trial date and harmless, and denied the chain‑of‑custody challenges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the suppression motion was timely under Rule 12(c)(1)(B).	State argued untimely filing.	Smith contends 'trial' means the actual trial date, not the initial scheduling.	Timeliness determined by actual trial date; error deemed harmless.
Whether the denial of the suppression motion was harmless error.	Undisputed facts negate suppression grounds.	Potential suppression issues could have yielded relief.	Harmless error; undisputed evidence defeats suppression argument.
Whether the chain‑of‑custody foundation for the crack pipe and cocaine was adequate.	Evidence properly authenticated and custody preserved.	Mislabeled evidence and gaps in custody require admission to be erroneous.	Admission not an abuse of discretion; chain of custody sufficient for admissibility, weight goes to jury.
Whether discrepancies in weight/description between seizure and lab report support tampering.	Lab weight and trial descriptions could be reconciled; no tampering proved.	Differences suggest substitution or contamination.	Differences affect weight/description only as weight/value, not admissibility.

State v. Sosa, 2011 UT 12 (Utah (2011)) (statutory/rule interpretation standard of correctness)
State v. MacGuire, 2004 UT 4 (Utah (2004)) (plain language approach to rules of procedure)
State v. Ramirez, 817 P.2d 774 (Utah (1991)) (benign denial of suppression merits when record silent on factual disputes)
State v. Lovegren, 798 P.2d 767 (Utah Ct.App.1990) (undisputed trial evidence may sustain suppression rulings)
State v. Wynia, 754 P.2d 667 (Utah Ct.App.1988) (weak link in chain of custody affects weight, not admissibility)
State v. Hagle Book, Inc., 583 P.2d 73 (Utah (1978)) (authentication by showing evidence not altered)
United States v. Clonts, 966 F.2d 1366 (10th Cir.1992) (identification suffices when evidence unique and readily identifiable)
United States v. Cardenas, 864 F.2d 1528 (10th Cir.1989) (need for detailed chain of custody when evidence is susceptible to tampering)