State v. Sanchez
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In this murder case, the Supreme Court clarified the correct standard for extreme emotional distress.
Defendant was convicted of first-degree murder for viciously torturing his girlfriend, ultimately causing her death. Defendant argued that he was under extreme emotional distress at the time of the murder. On appeal, the court of appeals concluded that the trial court abused its discretion by not admitting statements under Utah R. Evid. 106 that Defendant made to a detective that he argued would have supported his claim for a reduced charge based on special mitigation for extreme emotional distress but that the error was harmless. The Supreme Court vacated the portions of the court of appeals’ decision that dealt with Rule 106 and the standard for extreme emotional distress, clarified the correct standard for extreme emotional distress, and affirmed the harmlessness determination of the court of appeals on affirmative grounds.
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