reach rule in Utah

7 Utah opinions name it 2 courts 2002–2026 2 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.

Followed or applied (3)

Case	Followed	Cited
State v. Maingreen utahctapp · 2021 · cited in 1 Utah opinions naming this issue, 2025–2025 2 sentences 2025But the 8 Cite as: 2025 UT 60 Opinion of the Court court of appeals has squarely held that “[e]vidence forming such an ‘integral part of the charged conduct’ is ‘beyond the reach of rule 404(b).’” State v. Sorenson, 2023 UT App 159 , ¶ 14, 542 P.3d 529 (quoting State v. Hood, 2018 UT App 236 , ¶¶ 32–33, 438 P.3d 54 ); see also State v. Main, 2021 UT App 81, ¶ 19 , 494 P.3d 1056 . ¶26 Blackwing characterizes the distinction between intrinsic and extrinsic evidence as “the intrinsic exception” to rule 404(b). 2025But the 8 Cite as: 2025 UT 60 Opinion of the Court court of appeals has squarely held that “[e]vidence forming such an ‘integral part of the charged conduct’ is ‘beyond the reach of rule 404(b).’” State v. Sorenson, 2023 UT App 159 , ¶ 14, 542 P.3d 529 (quoting State v. Hood, 2018 UT App 236 , ¶¶ 32–33, 438 P.3d 54 ); see also State v. Main, 2021 UT App 81, ¶ 19 , 494 P.3d 1056 . ¶26 Blackwing characterizes the distinction between intrinsic and extrinsic evidence as “the intrinsic exception” to rule 404(b).	1	1
United States v. Parkergreen ca10 · 2009 · cited in 1 Utah opinions naming this issue, 2025–2025 1 sentence 2025He argues that the intrinsic exception is a reincarnation of the English common law doctrine of res gestae, which functioned as an exception to the general common law prohibition against the “use of character or propensity evidence to establish a defendant’s guilt.” In his view, the intrinsic exception improperly “exempts from Rule 404(b) scrutiny any ‘evidence [that] is directly connected to the factual circumstances of the crime and provides contextual or background information to the jury.’” (Quoting United States v. Parker, 553 F.3d 1309, 1314 (10th Cir. 2009).) He urges us to follow the p	1	1
Maltman v. Sauergreen wash · 1975 · cited in 1 Utah opinions naming this issue, 2007–2007 2 sentences 2007See Maltman v. Sauer, 84 Wash.2d 975 , 530 P.2d 254, 257 (1975) (presenting both rules and holding that "a professional rescuer, in making a deliberate attempt at saving a life, and under the correct factual setting, is within the intended scope of the `rescue doctrine'"). 2007See Maltman v. Sauer, 84 Wash.2d 975 , 530 P.2d 254, 257 (1975) (presenting both rules and holding that "a professional rescuer, in making a deliberate attempt at saving a life, and under the correct factual setting, is within the intended scope of the `rescue doctrine'").	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Utah. Read the followed side critically anyway.

Also cited on this issue (8)

Case	Cited	Years
State v. Murphy green utahctapp · 2019 1 sentence 2026As substantive support for its analysis, the court then proffers that the rules of evidence are intended to support “an inclusionary approach to admitting evidence under rule 404(b),” see id.—thus quickly resolving, in a couple sentences and while citing only the rules themselves, a complex historical debate about the reach of rule 404(b), see Murphy, 2019 UT App 64 , ¶ 48 n.16 (Harris, J., concurring) (describing the long debate over whether federal rule 404(b) is a rule of inclusion or a rule of exclusion) 8—and points 8.	1	2026–2026
State v. Hood green utahctapp · 2018 2 sentences 2025But the 8 Cite as: 2025 UT 60 Opinion of the Court court of appeals has squarely held that “[e]vidence forming such an ‘integral part of the charged conduct’ is ‘beyond the reach of rule 404(b).’” State v. Sorenson, 2023 UT App 159 , ¶ 14, 542 P.3d 529 (quoting State v. Hood, 2018 UT App 236 , ¶¶ 32–33, 438 P.3d 54 ); see also State v. Main, 2021 UT App 81, ¶ 19 , 494 P.3d 1056 . ¶26 Blackwing characterizes the distinction between intrinsic and extrinsic evidence as “the intrinsic exception” to rule 404(b). 2025But the 8 Cite as: 2025 UT 60 Opinion of the Court court of appeals has squarely held that “[e]vidence forming such an ‘integral part of the charged conduct’ is ‘beyond the reach of rule 404(b).’” State v. Sorenson, 2023 UT App 159 , ¶ 14, 542 P.3d 529 (quoting State v. Hood, 2018 UT App 236 , ¶¶ 32–33, 438 P.3d 54 ); see also State v. Main, 2021 UT App 81, ¶ 19 , 494 P.3d 1056 . ¶26 Blackwing characterizes the distinction between intrinsic and extrinsic evidence as “the intrinsic exception” to rule 404(b).	1	2025–2025
State v. Blackwing green utah · 2025 1 sentence 2025But the 8 Cite as: 2025 UT 60 Opinion of the Court court of appeals has squarely held that “[e]vidence forming such an ‘integral part of the charged conduct’ is ‘beyond the reach of rule 404(b).’” State v. Sorenson, 2023 UT App 159 , ¶ 14, 542 P.3d 529 (quoting State v. Hood, 2018 UT App 236 , ¶¶ 32–33, 438 P.3d 54 ); see also State v. Main, 2021 UT App 81, ¶ 19 , 494 P.3d 1056 . ¶26 Blackwing characterizes the distinction between intrinsic and extrinsic evidence as “the intrinsic exception” to rule 404(b).	1	2025–2025
cluster 537185 green ca10 · 1990 1 sentence 2016Thus, reverse, piercing should be a tool of last resort; too-frequent imposition of such liability could "bypass[ ] normal judgment-collection procedures" in a manner prejudicing "non-culpable shareholders." Cascade Energy, 896 F.2d at 1577 . ~T80 As a practical matter, this principle of habﬂlty has teeth only for individual acts falling beyond the reach of the doctrine of respondeat superior.	1	2016–2016
Holmes Development, LLC v. Cook green utah · 2002 2 sentences 2015Our supreme court has further held that two corporations that had the same management and 110 were "practically indistinguishable" were nevertheless separate entities and thus "refuse[d] to recognize them as the same entity for standing to sue on a contract." Holmes Dev., LLC v. Cook, 2002 UT 38 , ¶ 53 n. 6, 48 P.3d 895 . 1 16 Defendants seek to avoid the reach of this principle by arguing that the cases illustrating it all involved deliberate attempts to operate as separate corporations. 2015Our supreme court has further held that two corporations that had the same management and 110 were "practically indistinguishable" were nevertheless separate entities and thus "refuse[d] to recognize them as the same entity for standing to sue on a contract." Holmes Dev., LLC v. Cook, 2002 UT 38 , ¶ 53 n. 6, 48 P.3d 895 . 1 16 Defendants seek to avoid the reach of this principle by arguing that the cases illustrating it all involved deliberate attempts to operate as separate corporations.	1	2015–2015
State v. Larsen green utah · 1993 2 sentences 2014Indeed, Larsen noted that "an integral element of a rule 702 determination to admit expert evidence is a balancing of the probativeness of the evidence against its potential for unfair prejudice" and that the balancing of those two factors "mimics that under rule 403 and is necessary to a determination of 'helpfulness.'" 865 P.2d at 1368 n. 12. 2014Indeed, Larsen noted that “an integral element of a rule 702 determination to admit expert evidence is a balancing of the probativeness of the evidence against its potential for unfair prejudice” and that the balancing of those two factors “mimics that under rule 403 and is necessary to a determination of ‘helpfulness.’” 865 P.2d at 1363 n.12.	1	2014–2014
Bruton v. United States green scotus · 1968 2 sentences 2002Id. at 208 , 107 S.Ct. 1702 (quoting Bruton, 391 U.S. at 124 n. 1, 135, 88 S.Ct. 1620 ). € 36 In Richardson, the Court clarified the reach of this exception. 2002Id. at 208 , 107 S.Ct. 1702 (quoting Bruton, 391 U.S. at 124 n. 1, 135, 88 S.Ct. 1620 ). € 36 In Richardson, the Court clarified the reach of this exception.	1	2002–2002
Richardson v. Marsh green scotus · 1987 2 sentences 2002Id. at 208 , 107 S.Ct. 1702 (quoting Bruton, 391 U.S. at 124 n. 1, 135, 88 S.Ct. 1620 ). € 36 In Richardson, the Court clarified the reach of this exception. 2002Id. at 208 , 107 S.Ct. 1702 (quoting Bruton, 391 U.S. at 124 n. 1, 135, 88 S.Ct. 1620 ). € 36 In Richardson, the Court clarified the reach of this exception.	1	2002–2002

Where else courts name it

CA 35 (1963–2025) NY 15 (1971–2011) LA 14 (1984–2015) FL 12 (1982–2025) NJ 11 (1973–2024) IL 9 (1967–2022) MD 8 (1926–2015) WA 7 (1904–2016) MA 7 (1977–2014) UT 7 (2002–2026) IA 6 (1977–2017) WY 5 (1981–2006) AK 4 (1967–2005) MI 4 (1975–2015) VA 4 (1988–2014) TX 4 (1966–2017) OR 3 (1981–2003) CT 3 (2005–2017) AZ 3 (1997–2018) TN 3 (2014–2018) DC 3 (1981–2002) OK 2 (2019–2019) ME 2 (2000–2016) MN 2 (1967–1985) WV 2 (2003–2016) ID 2 (1943–2007) VT 2 (2016–2024) PA 2 (2002–2021) IN 2 (2006–2023) OH 2 (2020–2021) MT 2 (2011–2015)

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.

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