Utah Court of Appeals
When can Utah courts exclude statements against interest under rule 804(b)(3)? State v. Farmer Explained
Summary
Farmer was convicted of aggravated murder, attempted aggravated murder, aggravated robbery, and obstructing justice after participating in a robbery where his co-defendant shot and killed one victim and wounded another. The trial court excluded co-defendant’s written and verbal statements exonerating Farmer under rule 804(b)(3) for lack of sufficient corroborating circumstances indicating trustworthiness.
Analysis
In State v. Farmer, the Utah Court of Appeals examined when trial courts may exclude hearsay statements under rule 804(b)(3) of the Utah Rules of Evidence, which provides an exception for statements against interest when the declarant is unavailable.
Background and Facts
Farmer and Viegas visited a friend’s home under the guise of purchasing Xanax but instead committed an armed robbery. Viegas shot both the friend and his brother, killing the brother. Following the crime, Farmer disposed of evidence including phones and socks. While incarcerated, Viegas allegedly sent a written statement and made verbal statements to another inmate claiming Farmer was unaware of the robbery plan and was coerced into participation. However, Viegas later denied authoring the written statement, claiming someone else used his login credentials.
Key Legal Issues
The primary issue was whether the trial court properly excluded the statements under rule 804(b)(3), which requires that statements against interest be “supported by corroborating circumstances that clearly indicate [their] trustworthiness.” Farmer also challenged the denial of a compulsion jury instruction for the obstruction charge and claimed ineffective assistance of counsel.
Court’s Analysis and Holding
The court applied an abuse of discretion standard to the trial court’s trustworthiness determination under rule 804(b)(3). The court emphasized that corroborating circumstances must do more than merely tend to indicate trustworthiness—”the inference of trustworthiness from the proffered corroborating circumstances must be strong, not merely allowable.” The trial court reasonably considered that Viegas denied authoring the written statement, login credentials were shared among inmates, and physical evidence contradicted claims that the victim was shot in a hallway rather than his bedroom.
Practice Implications
This decision underscores the high evidentiary threshold for admitting statements against interest in criminal cases. Practitioners must present compelling corroborating circumstances that create a strong inference of trustworthiness. The court’s deferential review means trial courts have significant discretion in making these determinations. Additionally, the decision reinforces that compulsion defenses require evidence of specific, imminent threats, and that unanimity instructions may be required when multiple acts could support a single charge.
Case Details
Case Name
State v. Farmer
Citation
2025 UT App 57
Court
Utah Court of Appeals
Case Number
No. 20210913-CA
Date Decided
April 24, 2025
Outcome
Affirmed
Holding
Trial court did not abuse its discretion in excluding hearsay statements under rule 804(b)(3) where corroborating circumstances did not clearly indicate trustworthiness, in denying compulsion instruction for obstructing justice where evidence lacked imminent threat, and counsel was not ineffective for failing to renew motions or request unanimity instruction where no prejudice shown.
Standard of Review
Abuse of discretion for trial court’s ruling on admissibility of evidence under rule 804(b)(3), abuse of discretion for refusal to give jury instruction (though constrained when party legally entitled to instruction), and ineffective assistance of counsel reviewed as matter of law when raised for first time on appeal
Practice Tip
When seeking to admit statements against interest under rule 804(b)(3), ensure corroborating circumstances create a strong—not merely allowable—inference of trustworthiness, as trial courts have broad discretion to exclude such evidence.
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