State of Utah, Plaintiff and Respondent v. Elroy Tillman, Defendant and Appellant

Summary

The Utah Supreme Court affirmed Tillman's first-degree murder conviction and death sentence, rejecting challenges based on prosecutorial comments, exclusion of polygraph evidence, sentencing argument, disproportionality, jury unanimity, merger, reasonable-doubt instructions, and jury-venire composition. The court held that any constitutional error in the prosecutor's comments was harmless beyond a reasonable doubt, that the polygraph evidence lacked a sufficient reliability foundation and was cumulative, and that the remaining claims lacked merit or were unsupported by the record. Separate opinions disagreed with portions of the reasoning concerning the life-sentence argument, jury unanimity on aggravating circumstances, and the merger doctrine, although the separate justices concurred in affirmance or in the result.