State of Utah, Plaintiff and Respondent v. Ronald Watson Lafferty, Defendant and Appellant

Summary

The court affirmed Lafferty’s convictions and death sentences, holding that he was competent to stand trial, had not validly waived counsel to invoke self-representation, and could control the substantive theory of his defense after making an informed choice. The court also held that errors involving gruesome photographs and the penalty-phase admission of unconvicted violent conduct did not require reversal because the evidence of guilt and the aggravating circumstances was overwhelming, while announcing prospective safeguards for using unconvicted violent crimes as aggravating factors. Justice Stewart, concurring in the convictions and dissenting as to the penalty, would have ordered a new penalty hearing because of the prosecutor’s argument about future killings and would have excluded evidence of unconvicted crimes.