State v. Stringham, 2013 UT App 15

Stringham was convicted at a jury trial of operating a vehicle without an ignition interlock system; other convictions (DUI and alcohol-restricted driver) were not challenged on appeal.
He argues the evidence is insufficient to support the ignition interlock conviction and that the issue was not properly preserved for appeal.
The State contends sufficiency claims must be preserved by motion or objection, but plain-error review applies if the issue is obvious; appellate review looks at the evidence in a light favorable to the verdict.
Officer testimony showed Stringham’s driver license required an interlock device, which was not in the vehicle; Stringham admitted being off probation and possibly not required to have interlock.
Trial evidence included that an interlock device, if correctly installed, would have prevented starting the vehicle while intoxicated; the officer’s initial belief about the device’s presence was later contradicted.
The court affirmed the conviction, finding the evidence sufficient and rejecting claims of plain error and ineffective assistance of counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preservation of insufficiency claim (plain error)	Stringham preserved the issue for appeal.	District court plain error could be raised if evident to the court.	No plain error; evidence sufficient.
Ineffective assistance of counsel	Counsel failed to challenge insufficiency.	Failure to raise would be futile given sufficiency.	Counsel did not render deficient performance; no prejudice.
Sufficiency of evidence to support ignition interlock conviction	Evidence was ambiguous about interlock presence.	Evidence and inferences supported conviction.	There was sufficient evidence to support the conviction.

State v. Smith, 909 P.2d 236 (Utah 1995) (ineffective assistance standard; sufficiency review principles)