The State of Utah, Plaintiff and Respondent v. Johnnie Patrick Knight, Defendant and Appellant

Summary

The court held that the prosecution violated its voluntary discovery commitment by failing to search prosecution-team files for the requested witness statements and by withholding updated contact information obtained before trial. Because the undisclosed material caused a credible risk that the defense was unable to prepare for pivotal testimony, and the trial court denied a continuance or mistrial, the court reversed Knight's conviction. The court also clarified that reversible error exists when the nondisclosure creates a reasonable likelihood of a more favorable result sufficient to undermine confidence in the verdict.