How should Utah courts evaluate jury instructions for accomplice liability? State v. Eyre Explained

In State v. Eyre, the Utah Court of Appeals addressed important questions about jury instructions and ineffective assistance of counsel in the context of accomplice liability for aggravated robbery.

Background and Facts

Matthew Eyre was charged with aggravated robbery under an accomplice liability theory after participating in an attempted carjacking in Salt Lake City. During the incident, Eyre’s co-defendant displayed a firearm and announced a robbery, but was ultimately shot and killed by the intended victim. Eyre fled the scene and was later arrested. At trial, the parties stipulated to admission of all exhibits, including a recording of Eyre’s police interview, which inadvertently went to the jury room during deliberations.

Key Legal Issues

Eyre raised two primary arguments on appeal: (1) his trial counsel was ineffective for failing to object to a jury instruction that allegedly misstated the mens rea requirement for accomplice liability, and (2) his motion for mistrial should have been granted after the jury viewed his police interview recording during deliberations. Alternatively, he argued counsel was ineffective for allowing the recording to reach the jury room.

Court’s Analysis and Holding

The court applied the standard two-prong test for ineffective assistance of counsel claims, requiring both deficient performance and prejudice. Regarding the jury instructions, the court emphasized that instructions must be evaluated “in their entirety” rather than in isolation. While acknowledging that one instruction could have been clearer, the court found that other instructions adequately conveyed the required mental state for accomplice liability. The court noted that Utah Code section 76-2-202 requires acting “with the mental state required for the commission of an offense,” and the jury instructions as a whole satisfied this requirement.

On the police interview issue, the court applied the invited error doctrine, finding that trial counsel had stipulated to admission of all exhibits and failed to object when the jury requested access to video exhibits. The court distinguished recordings of defendants’ statements from testimonial evidence of other witnesses, noting that several jurisdictions permit jury access to such recordings during deliberations.

Practice Implications

This decision reinforces that Utah courts will evaluate jury instructions holistically rather than focusing on potentially problematic isolated language. For practitioners, this underscores the importance of reviewing all jury instructions collectively when preparing for trial or mounting appellate challenges. The ruling also clarifies that defendants’ recorded statements to police are generally permissible in jury deliberations, unlike testimonial evidence from other witnesses. Additionally, the invited error doctrine serves as a powerful bar to appellate relief when counsel’s strategic decisions contribute to the alleged error.