State of Utah, Plaintiff and Appellee v. Sean Hale Holgate, Defendant and Appellant

Summary

The Utah Supreme Court affirmed Holgate’s convictions for murder and aggravated burglary. Although sufficiency claims generally must be preserved in the trial court, they may be reviewed for plain error when the evidence is insufficient and the deficiency is so obvious and fundamental that submitting the case to the jury was erroneous. The court held that reasonable inferences from Holgate’s conduct supported both convictions.