State v. Taylor, 539 P.3d 351

Taylor, a former employee of a research institute, and a colleague (Colleague) are geologists; after Taylor was fired, Colleague reported a disturbing interaction at a professional conference to her supervisor and police.
A summary of Colleague’s statement (describing Taylor blocking her path and acting "irate and unstable") was included in the probable cause statement of an unrelated Information filed against Taylor.
Immediately after his arraignment on the other charges, Taylor emailed Colleague multiple times accusing her of lying, attaching the Information summary, and asking her to "please renounce your statement," noting he faced prison, fines, and a permanent record.
The State charged Taylor with one count of witness tampering (third-degree felony). At trial Colleague testified she was "scared" by the emails and considered recanting; Taylor testified he believed she lied and asked her to correct the record.
A jury convicted Taylor; before sentencing the district court arrested judgment, finding insufficient evidence of the requisite mens rea (in part because it concluded Colleague’s testimony about fear was admitted in error).
The State appealed; the Court of Appeals held the district court erred by not viewing the evidence in the light most favorable to the verdict and reversed, instructing reinstatement of the jury’s verdict.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Taylor)	Held
Whether the evidence was sufficient to prove Taylor had the requisite mens rea (intent/knowledge/recklessness) to commit witness tampering by inducing false testimony or withholding testimony	The district court improperly substituted its view for the jury’s; construed favorably, the emails and context support a reasonable inference Taylor sought to induce Colleague to recant or withhold testimony	The emails reflect a genuine dispute about what happened (difference of perception) and an exhortation to tell the truth, not an intent to induce false testimony or to withhold it; Colleague’s fear testimony was erroneously admitted and pivotal	Reversed: viewing all evidence in the light most favorable to the verdict, a reasonable jury could infer Taylor knowingly/ intentionally/ recklessly attempted to induce Colleague to testify falsely or to withhold testimony; arrest of judgment was improper; reinstate verdict

State v. Black, 344 P.3d 644 (Utah Ct. App. 2015) (standard for arresting judgment; review requires viewing evidence most favorably to verdict)
State v. Stricklan, 477 P.3d 1251 (Utah 2020) (sufficiency review defers to jury and requires assessing cumulative evidence and reasonable inferences)
State v. Plexico, 376 P.3d 1080 (Utah Ct. App. 2016) (tampering conviction supported where defendant asked witness to adopt a version plainly incompatible with evidence)
State v. Mitchell, 318 P.3d 238 (Utah Ct. App. 2013) (intent or knowledge may be inferred from circumstantial evidence)
State v. Florez, 465 P.3d 307 (Utah Ct. App. 2020) (framework for proving mental state by circumstantial evidence)
State v. Whytock, 469 P.3d 1150 (Utah Ct. App. 2020) (mental-state requirements for criminal liability)
State v. Burk, 839 P.2d 880 (Utah Ct. App. 1992) (defendant who asked witness to testify that witness knew nothing attempted to induce withholding/false testimony)
State v. Garrido, 314 P.3d 1014 (Utah Ct. App. 2013) (discusses prior testimony exception and consequences when witness refuses to testify)