State v. Vigil, 448 P.3d 738

Defendant Erika Vigil fled an assault by her live-in boyfriend, who then brandished a gun at the victim and stole the victim’s phone and wallet; Defendant handled the victim’s phone and provided misleading information to officers on scene.
Defendant repeatedly denied knowing her boyfriend and gave a false name and false address to police, delaying identification of the suspect for over a week.
Surveillance footage later identified the boyfriend, and police connected him to Defendant as his cohabitant.
Defendant was charged with obstruction of justice and tried by jury; at the instruction conference her trial counsel approved Instruction 28, which described the mental-state elements for obstruction ("knowingly or intentionally" and "with intent to hinder, delay, or prevent").
Defendant was convicted and appealed, asserting ineffective assistance of counsel because trial counsel failed to object to Instruction 28, which she argued misstated the mens rea requirement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for approving Instruction 28	State: Trial counsel’s approval was not deficient because the instruction accurately stated the law	Vigil: Instruction 28 conflated mens rea by allowing conviction on "knowingly" when obstruction requires specific intent	Court: Counsel was not ineffective; Instruction 28 fairly and accurately instructed on both general mens rea and specific intent

Strickland v. Washington, 466 U.S. 668 (ineffective assistance two-part test)
State v. Bird, 345 P.3d 1141 (Utah 2015) (instruction must state required mens rea and distinguish general vs specific intent)
State v. Maughan, 305 P.3d 1058 (Utah 2013) (obstruction is a specific-intent crime)
State v. Liti, 355 P.3d 1078 (Utah Ct. App. 2015) (counsel not deficient for approving correct jury instructions)
State v. Lopez, 438 P.3d 950 (Utah Ct. App. 2019) (standard for assessing ineffective-assistance claims raised on appeal)