State v. Paule
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In a case before the Supreme Court of the State of Utah, the petitioner, Elbert John Paule, was charged with murder, obstruction of justice, reckless endangerment, and assault following a fatal shooting incident involving a friend. The jury acquitted Paule on all charges except obstruction of justice. Paule challenged his conviction, arguing that the obstruction of justice conviction was legally inconsistent with the jury’s determination that he was not guilty of the other crimes. The Utah Court of Appeals affirmed the conviction. On certiorari review, the Supreme Court of the State of Utah affirmed the lower court's ruling.
The Supreme Court held that to be convicted of obstruction of justice, a defendant need only perform an obstructive act with the requisite intent. Proof of a separate crime is not necessary. The court concluded that because a violation of Utah’s obstruction of justice statute requires only that a defendant act with the requisite intent—it does not require proof of a separate criminal offense—the jury’s verdict was not legally impossible. Furthermore, the court found that Paule's counsel was not constitutionally ineffective in failing to seek a more detailed unanimity instruction.
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