State of Utah, Plaintiff and Appellee v. Ralph Leroy Menzies, Defendant and Appellant

Summary

The Utah Supreme Court affirmed Menzies's capital-murder conviction and death sentence. It overruled Utah's automatic-reversal rule for the compelled use of a peremptory challenge, found no prejudicial discovery violation or confrontation violation, and rejected the penalty-phase challenges under applicable harmless-error and plain-error standards. Justice Stewart, concurring in part and dissenting in part, would permit reversal upon a showing of actual prejudice and would have addressed additional alleged errors, including the reasonable-doubt instruction and admission of the prison record.