Can vague criminal statutes survive constitutional challenge in Utah? State v. Mattinson Explained

In State v. Mattinson, the Utah Supreme Court addressed fundamental questions about when criminal statutes become too vague to satisfy constitutional requirements. The case arose when Richard Mattinson was convicted of communications fraud after providing false information to help a friend avoid arrest while seeking emergency medical treatment.

Background and Facts

Mattinson accompanied his friend Stevoni Wells to Utah Valley Regional Medical Center for emergency treatment. Wells feared arrest on outstanding warrants, so she provided false identifying information. Mattinson falsely claimed to be her husband and signed a consent form for her treatment, which also made him liable for payment of medical bills. The State charged Mattinson with communications fraud under Utah Code section 76-10-1801.

Key Legal Issues

Mattinson challenged the Communications Fraud statute on two constitutional grounds: overbreadth and vagueness. The court reviewed whether the statute criminalized protected speech and whether its language provided adequate notice of prohibited conduct.

Court’s Analysis and Holding

The Utah Supreme Court rejected the overbreadth challenge, finding that knowingly false statements made to execute fraudulent schemes receive no First Amendment protection. However, the court struck down subsection (1)(e) for vagueness. The problematic language “other than the obtaining of something of monetary value” failed to provide adequate notice of what conduct was criminalized. The court noted that even prosecutors offered conflicting interpretations during trial, demonstrating the provision’s constitutional deficiency.

Practice Implications

This decision illustrates that criminal statutes must provide fair notice to ordinary citizens about prohibited conduct. When statutory language admits multiple reasonable interpretations, particularly regarding the elements of an offense, constitutional due process may be violated. The court’s approach of severing only the unconstitutional provision while preserving the statute’s core demonstrates judicial restraint in constitutional interpretation.