Are good faith jury instructions required in Utah fraud cases? State v. Stringham Explained

In State v. Stringham, the Utah Court of Appeals addressed whether trial courts must give good faith jury instructions in fraud cases when defendants claim they acted without criminal intent. This case of first impression established important precedent for Utah criminal practice.

Background and Facts

Robert and Gale Stringham operated Utah Treatment and Addiction Health Services, a counseling organization. They hired Dr. Charles Walton, a licensed physician, to facilitate a domestic violence group. Dr. Walton provided his signature stamp to facilitate billing for his patients only. However, the Stringhams used Dr. Walton’s signature stamp on virtually all insurance forms from their Salt Lake office, billing for services Dr. Walton neither provided nor supervised. Both defendants were convicted of communications fraud and racketeering.

Key Legal Issues

The defendants raised three arguments on appeal: whether the trial court erred in refusing to enforce a tentative plea agreement, whether the court should have given a good faith jury instruction regarding the fraud charges, and whether sufficient evidence supported Gale Stringham’s conviction.

Court’s Analysis and Holding

The court rejected the minority position requiring good faith instructions in fraud cases. Following the majority rule, the court held that when detailed jury instructions already address the required mental state elements—intentionally, knowingly, or with reckless disregard for truth—a separate good faith instruction is redundant. The court explained that if a jury finds a defendant acted knowingly and willfully, this finding is inconsistent with good faith. The court also affirmed that tentative plea agreements not formally presented to or accepted by the trial court are unenforceable, and found sufficient evidence supported both defendants’ convictions.

Practice Implications

This decision clarifies that Utah follows the majority approach on good faith instructions, providing certainty for practitioners defending fraud cases. While courts may exercise discretion to give such instructions, their absence is not reversible error when proper mental state instructions are provided. Defense counsel should focus on challenging the sufficiency of evidence regarding criminal intent rather than relying on specialized jury instructions.