Must trial courts make findings about disputed facts in presentence reports? State v. Maroney Explained

In State v. Maroney, the Utah Court of Appeals clarified trial courts’ obligations when parties dispute the accuracy of information contained in presentence investigation reports. This decision provides important guidance for practitioners handling criminal sentencing matters.

Background and Facts

Maroney pleaded guilty to sexual abuse of a minor and lewdness involving a child after inappropriate conduct with a twelve-year-old boy. The presentence investigation revealed a pattern of prior sexual abuse involving his stepsons and included allegations of domestic violence. Defense counsel challenged two aspects of the sentencing reports: the nature and extent of Maroney’s prior treatment at Davis County Mental Health, and the characterization of his violent behavior based on ex-wife and stepson accounts.

Key Legal Issues

The central issue was whether the trial court complied with Utah Code § 77-18-1(6)(a), which requires sentencing judges to resolve contested information in presentence reports. Defense counsel explicitly asked the court to use its “fact-finding function” to resolve discrepancies about treatment history and challenged the reliability of violence allegations.

Court’s Analysis and Holding

The Court of Appeals held that when parties properly challenge the accuracy of presentence report information, trial courts must “make findings on the record as to whether the information objected to is accurate” and determine its relevance to sentencing. The court found that defense counsel had sufficiently challenged both the treatment history and violence characterizations, but the trial court failed to make the required findings.

Practice Implications

This decision emphasizes the importance of formal objections to disputed presentence report information. Practitioners must not only identify inaccuracies but explicitly request judicial findings. The court noted that failure to challenge accuracy at sentencing results in waiver under § 77-18-1(6)(b). When proper objections are made, appellate courts will remand if trial courts fail to resolve them, potentially allowing sentence modification if the findings affect the court’s sentencing decision.