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7 Utah opinions name it 2 courts 2020–2026 6 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 |
|---|---|---|
State v. Greengreen1 sentence2026The court begins by stating that “the plain text of the rule, in conjunction with the other rules of evidence, suggests that [prior-bad-acts] evidence may be admissible to rebut a fabrication defense,” Green, 2023 UT 10, ¶ 70 (emphasis added); the court’s use of the verb “suggests” is telling and itself suggests that the text of the rule might not be quite as “plain” as the court describes. | 1 | 1 |
State v. Harrisgreen2 sentences2025See id. ¶26 Under section 77-20-209, a defendant has a right to appeal when the court “issues a pretrial status order that orders the individual be detained during the time the individual awaits trial or other resolution of criminal charges.” The October 2024 order denying Harris’s motion for pretrial release fell within the terms of the statute because it was a pretrial status order that ordered Harris detained pending trial. 2025And where a plain text analysis reveals an answer 8 Cite as: 2025 UT 48 Opinion of the Court to the statutory interpretation question before us, we need not make use of other interpretative tools. | 1 | 1 |
State v. Ramseygreen2 sentences2021See State v. Stricklan, 2020 UT 65 , ¶ 69 n.10, 477 P.3d 1251 ; see also State v. Ramsey, 782 P.2d 480, 484 (Utah 1989) (“Utah Rule of Evidence 801(d)(1)(A) acts more broadly to admit out-of-court statements or substantive evidence than its federal counterpart because the Utah rule does not require the out-of-court statement to be under oath.”). not impeach its own witness except under special circumstances, such as when a witness “unexpectedly and without explanation contradicts his or her prior testimony.” Id. 2021See State v. Stricklan, 2020 UT 65 , ¶ 69 n.10, 477 P.3d 1251 ; see also State v. Ramsey, 782 P.2d 480, 484 (Utah 1989) (“Utah Rule of Evidence 801(d)(1)(A) acts more broadly to admit out-of-court statements or substantive evidence than its federal counterpart because the Utah rule does not require the out-of-court statement to be under oath.”). not impeach its own witness except under special circumstances, such as when a witness “unexpectedly and without explanation contradicts his or her prior testimony.” Id. | 1 | 1 |
State v. Stricklangreen2 sentences2021See State v. Stricklan, 2020 UT 65 , ¶ 69 n.10, 477 P.3d 1251 ; see also State v. Ramsey, 782 P.2d 480, 484 (Utah 1989) (“Utah Rule of Evidence 801(d)(1)(A) acts more broadly to admit out-of-court statements or substantive evidence than its federal counterpart because the Utah rule does not require the out-of-court statement to be under oath.”). not impeach its own witness except under special circumstances, such as when a witness “unexpectedly and without explanation contradicts his or her prior testimony.” Id. 2021See State v. Stricklan, 2020 UT 65 , ¶ 69 n.10, 477 P.3d 1251 ; see also State v. Ramsey, 782 P.2d 480, 484 (Utah 1989) (“Utah Rule of Evidence 801(d)(1)(A) acts more broadly to admit out-of-court statements or substantive evidence than its federal counterpart because the Utah rule does not require the out-of-court statement to be under oath.”). not impeach its own witness except under special circumstances, such as when a witness “unexpectedly and without explanation contradicts his or her prior testimony.” Id. | 1 | 1 |
State v. Leeyellow2 sentences2020See State v. Wilder, 2018 UT 17, ¶¶ 25, 33, 38 , 420 P.3d 1064 (disavowing the test set forth in State v. Finlayson, 2000 UT 10 , 994 P.2d 1243 , and State v. Lee, 2006 UT 5 , 128 P.3d 1179 , and instead applying the plain language of Utah’s merger statute); State v. Lucero, 2014 UT 15, ¶ 32 , 328 P.3d 841 (holding that the plain text of rule 403 of the Utah Rules of Evidence override the factors set forth in our decision in State v. Shickles, 760 P.2d 291 , 295-96 (Utah 1988), abrogated on other grounds by State v. Thornton, 2017 UT 9 , 391 P.3d 1016 ). 2020See State v. Wilder, 2018 UT 17, ¶¶ 25, 33, 38 , 420 P.3d 1064 (disavowing the test set forth in State v. Finlayson, 2000 UT 10 , 994 P.2d 1243 , and State v. Lee, 2006 UT 5 , 128 P.3d 1179 , and instead applying the plain language of Utah’s merger statute); State v. Lucero, 2014 UT 15, ¶ 32 , 328 P.3d 841 (holding that the plain text of rule 403 of the Utah Rules of Evidence override the factors set forth in our decision in State v. Shickles, 760 P.2d 291 , 295-96 (Utah 1988), abrogated on other grounds by State v. Thornton, 2017 UT 9 , 391 P.3d 1016 ). | 1 | 1 |
State v. Finlaysonred2 sentences2020See State v. Wilder, 2018 UT 17, ¶¶ 25, 33, 38 , 420 P.3d 1064 (disavowing the test set forth in State v. Finlayson, 2000 UT 10 , 994 P.2d 1243 , and State v. Lee, 2006 UT 5 , 128 P.3d 1179 , and instead applying the plain language of Utah’s merger statute); State v. Lucero, 2014 UT 15, ¶ 32 , 328 P.3d 841 (holding that the plain text of rule 403 of the Utah Rules of Evidence override the factors set forth in our decision in State v. Shickles, 760 P.2d 291 , 295-96 (Utah 1988), abrogated on other grounds by State v. Thornton, 2017 UT 9 , 391 P.3d 1016 ). 2020See State v. Wilder, 2018 UT 17, ¶¶ 25, 33, 38 , 420 P.3d 1064 (disavowing the test set forth in State v. Finlayson, 2000 UT 10 , 994 P.2d 1243 , and State v. Lee, 2006 UT 5 , 128 P.3d 1179 , and instead applying the plain language of Utah’s merger statute); State v. Lucero, 2014 UT 15, ¶ 32 , 328 P.3d 841 (holding that the plain text of rule 403 of the Utah Rules of Evidence override the factors set forth in our decision in State v. Shickles, 760 P.2d 291 , 295-96 (Utah 1988), abrogated on other grounds by State v. Thornton, 2017 UT 9 , 391 P.3d 1016 ). | 1 | 1 |
State v. Wildergreen2 sentences2020See State v. Wilder, 2018 UT 17, ¶¶ 25, 33, 38 , 420 P.3d 1064 (disavowing the test set forth in State v. Finlayson, 2000 UT 10 , 994 P.2d 1243 , and State v. Lee, 2006 UT 5 , 128 P.3d 1179 , and instead applying the plain language of Utah’s merger statute); State v. Lucero, 2014 UT 15, ¶ 32 , 328 P.3d 841 (holding that the plain text of rule 403 of the Utah Rules of Evidence override the factors set forth in our decision in State v. Shickles, 760 P.2d 291 , 295-96 (Utah 1988), abrogated on other grounds by State v. Thornton, 2017 UT 9 , 391 P.3d 1016 ). 2020See State v. Wilder, 2018 UT 17, ¶¶ 25, 33, 38 , 420 P.3d 1064 (disavowing the test set forth in State v. Finlayson, 2000 UT 10 , 994 P.2d 1243 , and State v. Lee, 2006 UT 5 , 128 P.3d 1179 , and instead applying the plain language of Utah’s merger statute); State v. Lucero, 2014 UT 15, ¶ 32 , 328 P.3d 841 (holding that the plain text of rule 403 of the Utah Rules of Evidence override the factors set forth in our decision in State v. Shickles, 760 P.2d 291 , 295-96 (Utah 1988), abrogated on other grounds by State v. Thornton, 2017 UT 9 , 391 P.3d 1016 ). | 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. Canal-Medina
green
1 sentence2026Indeed, the plain text of the rule states that when a criminal defendant is accused of child molestation, evidence of “any other acts of child molestation” is admissible to prove “propensity to commit the crime charged.” Id. | 1 | 2026–2026 |
State v. Murphy
green
1 sentence2026As 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 |
Mottaghian v. State
green
1 sentence2023Rule 5(a) was amended effective May 1, 2023, and states that a petition must be “filed and served . . . within 21 days after the entry of the trial court’s order,” clarifying that the 21 days applies to the filing of the petition. 20230235-CA 2 2023 UT App 64 Mottaghian v. State And we acknowledge that this circumstance is unfortunate. 2 But the time period in question, under the plain text of the rule, runs from the time the court’s order was entered, not from when that order was served. | 1 | 2023–2023 |
Griffin v. Snow Christensen and Martineau
green
1 sentence2023It is only now, with its reading of In re Schwenke, that the majority is opening those floodgates. 20210494-CA 20 2023 UT App 88 Griffin v. Snow Christensen of the business—as contemplated by the plain text of rule 4(d)(1)(E)—provides clear direction to litigants and district courts as to whom a plaintiff may properly serve. | 1 | 2023–2023 |
State v. Shickles
green
1 sentence2020See State v. Wilder, 2018 UT 17, ¶¶ 25, 33, 38 , 420 P.3d 1064 (disavowing the test set forth in State v. Finlayson, 2000 UT 10 , 994 P.2d 1243 , and State v. Lee, 2006 UT 5 , 128 P.3d 1179 , and instead applying the plain language of Utah’s merger statute); State v. Lucero, 2014 UT 15, ¶ 32 , 328 P.3d 841 (holding that the plain text of rule 403 of the Utah Rules of Evidence override the factors set forth in our decision in State v. Shickles, 760 P.2d 291 , 295-96 (Utah 1988), abrogated on other grounds by State v. Thornton, 2017 UT 9 , 391 P.3d 1016 ). | 1 | 2020–2020 |
State v. Thornton
green
2 sentences2020See State v. Wilder, 2018 UT 17, ¶¶ 25, 33, 38 , 420 P.3d 1064 (disavowing the test set forth in State v. Finlayson, 2000 UT 10 , 994 P.2d 1243 , and State v. Lee, 2006 UT 5 , 128 P.3d 1179 , and instead applying the plain language of Utah’s merger statute); State v. Lucero, 2014 UT 15, ¶ 32 , 328 P.3d 841 (holding that the plain text of rule 403 of the Utah Rules of Evidence override the factors set forth in our decision in State v. Shickles, 760 P.2d 291 , 295-96 (Utah 1988), abrogated on other grounds by State v. Thornton, 2017 UT 9 , 391 P.3d 1016 ). 2020See State v. Wilder, 2018 UT 17, ¶¶ 25, 33, 38 , 420 P.3d 1064 (disavowing the test set forth in State v. Finlayson, 2000 UT 10 , 994 P.2d 1243 , and State v. Lee, 2006 UT 5 , 128 P.3d 1179 , and instead applying the plain language of Utah’s merger statute); State v. Lucero, 2014 UT 15, ¶ 32 , 328 P.3d 841 (holding that the plain text of rule 403 of the Utah Rules of Evidence override the factors set forth in our decision in State v. Shickles, 760 P.2d 291 , 295-96 (Utah 1988), abrogated on other grounds by State v. Thornton, 2017 UT 9 , 391 P.3d 1016 ). | 1 | 2020–2020 |
State v. Lucero
yellow
2 sentences2020See State v. Wilder, 2018 UT 17, ¶¶ 25, 33, 38 , 420 P.3d 1064 (disavowing the test set forth in State v. Finlayson, 2000 UT 10 , 994 P.2d 1243 , and State v. Lee, 2006 UT 5 , 128 P.3d 1179 , and instead applying the plain language of Utah’s merger statute); State v. Lucero, 2014 UT 15, ¶ 32 , 328 P.3d 841 (holding that the plain text of rule 403 of the Utah Rules of Evidence override the factors set forth in our decision in State v. Shickles, 760 P.2d 291 , 295-96 (Utah 1988), abrogated on other grounds by State v. Thornton, 2017 UT 9 , 391 P.3d 1016 ). 2020See State v. Wilder, 2018 UT 17, ¶¶ 25, 33, 38 , 420 P.3d 1064 (disavowing the test set forth in State v. Finlayson, 2000 UT 10 , 994 P.2d 1243 , and State v. Lee, 2006 UT 5 , 128 P.3d 1179 , and instead applying the plain language of Utah’s merger statute); State v. Lucero, 2014 UT 15, ¶ 32 , 328 P.3d 841 (holding that the plain text of rule 403 of the Utah Rules of Evidence override the factors set forth in our decision in State v. Shickles, 760 P.2d 291 , 295-96 (Utah 1988), abrogated on other grounds by State v. Thornton, 2017 UT 9 , 391 P.3d 1016 ). | 1 | 2020–2020 |
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.