8 Utah opinions name it 2 courts 1991–2025 3 in the last five years
The cases below were cited by Utah courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
United States v. Agursgreen2 sentences2025In United States v. Agurs, the Court spoke broadly about “the rule of Brady v. Maryland,” and observed that it “arguably applies in three quite different situations,” each involving “the discovery, after trial of information which had been known to the prosecution but unknown to the defense.” 427 U.S. 97, 103 (1976). ¶92 The first situation the Court identified was where “the undisclosed evidence demonstrates that the prosecution’s case includes perjured testimony and that the prosecution knew, or should have known, of the perjury.” Id. 2025In United States v. Agurs, the Court spoke broadly about “the rule of Brady v. Maryland,” and observed that it “arguably applies in three quite different situations,” each involving “the discovery, after trial of information which had been known to the prosecution but unknown to the defense.” 427 U.S. 97, 103 (1976). ¶92 The first situation the Court identified was where “the undisclosed evidence demonstrates that the prosecution’s case includes perjured testimony and that the prosecution knew, or should have known, of the perjury.” Id. | 1 | 2 |
Becker v. Beckergreen2 sentences2020See O’Hearon, 2017 UT App 214, ¶ 10 ; cf. Becker v. Becker, 694 P.2d 608, 610 (Utah 1984) (stating that, to meet the materiality requirement, the change in circumstances must “have some material relationship to and substantial effect on parenting ability or the functioning of the presently existing custodial relationship” or “appear on their face to be the kind of circumstances on which an earlier custody decision was based”). ¶36 But because a determination of whether “substantial and material changes have occurred is a fact-intensive legal determination,” see Doyle v. Doyle, 2009 UT App 306, 1991In the absence of an indication that the change has or will have such effect, the materiality requirement is not met.” Becker, 694 P.2d at 610 . | 1 | 2 |
Carter v. Stategreen2 sentences2025See Carter v. State, 2019 UT 12, ¶ 55 , 439 P.3d 616 (explaining that “the materiality standard under Brady is the same materiality standard contained in the PCRA”); see also Arriaga, 2020 UT 37 , ¶ 31 n.37 (explaining that by employing “term of art” legal tests, the PCRA incorporates the “accompanying well-developed body of . . . jurisprudence”). 2025See Carter v. State, 2019 UT 12, ¶ 55 , 439 P.3d 616 (explaining that “the materiality standard under Brady is the same materiality standard contained in the PCRA”); see also Arriaga, 2020 UT 37 , ¶ 31 n.37 (explaining that by employing “term of art” legal tests, the PCRA incorporates the “accompanying well-developed body of . . . jurisprudence”). | 1 | 1 |
Arriaga v. Stategreen1 sentence2025See Carter v. State, 2019 UT 12, ¶ 55 , 439 P.3d 616 (explaining that “the materiality standard under Brady is the same materiality standard contained in the PCRA”); see also Arriaga, 2020 UT 37 , ¶ 31 n.37 (explaining that by employing “term of art” legal tests, the PCRA incorporates the “accompanying well-developed body of . . . jurisprudence”). | 1 | 1 |
State v. Verdegreen2 sentences2021To meet the materiality element of admissibility under the doctrine of chances, “[t]he issue for which the uncharged misconduct evidence is offered ‘must be in bona fide dispute.’” Verde, 2012 UT 60, ¶ 57 (citation omitted). admit the evidence, the State has not asked us to affirm the court of appeals on this basis. 2021See 2012 UT 60 , ¶¶ 21–22. | 1 | 1 |
O'Hearon v. Hansengreen1 sentence2020See O’Hearon, 2017 UT App 214, ¶ 10 ; cf. Becker v. Becker, 694 P.2d 608, 610 (Utah 1984) (stating that, to meet the materiality requirement, the change in circumstances must “have some material relationship to and substantial effect on parenting ability or the functioning of the presently existing custodial relationship” or “appear on their face to be the kind of circumstances on which an earlier custody decision was based”). ¶36 But because a determination of whether “substantial and material changes have occurred is a fact-intensive legal determination,” see Doyle v. Doyle, 2009 UT App 306, | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Utah. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Betony
green
2 sentences2021Indeed, on appeal, Betony does not provide specific examples other than to generally state that the Magellan records “would have supported or, at a minimum, given the defense, its witnesses and the court the entire evidentiary picture rather than one having to be pieced together from various sources with holes as to the actual written history.” ¶39 For the foregoing reasons, the Magellan records did not satisfy the materiality standard, and therefore the exception outlined in rule 506(d)(1)(A) did not apply to those privileged 20190357-CA 18 2021 UT App 15 State v. Betony documents so as to re 2021CONCLUSION ¶40 Because there is no reasonable probability that the outcome of Betony’s trial would have been different had he obtained access to the Magellan records, those records were not material, and the trial court did not err in denying Betony’s request for their disclosure. ¶41 Affirmed. 20190357-CA 19 2021 UT App 15 | 1 | 2021–2021 |
State v. Worthen
green
1 sentence2021“In terms of the reasonable certainty test, ‘material’ refers to evidence in the records that is exculpatory, or in other words, favorable to the defense.” Worthen, 2009 UT 79, ¶ 48 . | 1 | 2021–2021 |
Doyle v. Doyle
green
2 sentences2020See O’Hearon, 2017 UT App 214, ¶ 10 ; cf. Becker v. Becker, 694 P.2d 608, 610 (Utah 1984) (stating that, to meet the materiality requirement, the change in circumstances must “have some material relationship to and substantial effect on parenting ability or the functioning of the presently existing custodial relationship” or “appear on their face to be the kind of circumstances on which an earlier custody decision was based”). ¶36 But because a determination of whether “substantial and material changes have occurred is a fact-intensive legal determination,” see Doyle v. Doyle, 2009 UT App 306, 2020See O’Hearon, 2017 UT App 214, ¶ 10 ; cf. Becker v. Becker, 694 P.2d 608, 610 (Utah 1984) (stating that, to meet the materiality requirement, the change in circumstances must “have some material relationship to and substantial effect on parenting ability or the functioning of the presently existing custodial relationship” or “appear on their face to be the kind of circumstances on which an earlier custody decision was based”). ¶36 But because a determination of whether “substantial and material changes have occurred is a fact-intensive legal determination,” see Doyle v. Doyle, 2009 UT App 306, | 1 | 2020–2020 |
Doyle v. Doyle
green
2 sentences2020See O’Hearon, 2017 UT App 214, ¶ 10 ; cf. Becker v. Becker, 694 P.2d 608, 610 (Utah 1984) (stating that, to meet the materiality requirement, the change in circumstances must “have some material relationship to and substantial effect on parenting ability or the functioning of the presently existing custodial relationship” or “appear on their face to be the kind of circumstances on which an earlier custody decision was based”). ¶36 But because a determination of whether “substantial and material changes have occurred is a fact-intensive legal determination,” see Doyle v. Doyle, 2009 UT App 306, 2020See O’Hearon, 2017 UT App 214, ¶ 10 ; cf. Becker v. Becker, 694 P.2d 608, 610 (Utah 1984) (stating that, to meet the materiality requirement, the change in circumstances must “have some material relationship to and substantial effect on parenting ability or the functioning of the presently existing custodial relationship” or “appear on their face to be the kind of circumstances on which an earlier custody decision was based”). ¶36 But because a determination of whether “substantial and material changes have occurred is a fact-intensive legal determination,” see Doyle v. Doyle, 2009 UT App 306, | 1 | 2020–2020 |
American Coal Co. v. Sandstrom
green
2 sentences1996Id. 1996Id. | 1 | 1996–1996 |
California v. Trombetta
green
2 sentences1993In order tc meet such a materiality requirement, the “evidence must both possess an exculpatory value that was apparent before the evidence was destroyed, and be of such a nature that the defendant would be unable to obtain comparable evidence by other reasonably available means.” Id. at 489 , 104 S.Ct. at 2534 . 1993In order tc meet such a materiality requirement, the “evidence must both possess an exculpatory value that was apparent before the evidence was destroyed, and be of such a nature that the defendant would be unable to obtain comparable evidence by other reasonably available means.” Id. at 489 , 104 S.Ct. at 2534 . | 1 | 1993–1993 |
Fullmer v. Fullmer
green
1 sentence1991Also, “only changes not contemplated by the parties at the time of divorce are relevant to the substantial *477 change test.” Crouse, 817 P.2d at 839 ; Fullmer, 761 P.2d at 947 . | 1 | 1991–1991 |
Crouse v. Crouse
green
1 sentence1991Also, “only changes not contemplated by the parties at the time of divorce are relevant to the substantial *477 change test.” Crouse, 817 P.2d at 839 ; Fullmer, 761 P.2d at 947 . | 1 | 1991–1991 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.