State v. Sisneros
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In this case involving to multiple prosecutions of Defendant for the robbery and theft of a used car the Supreme Court affirmed the judgment of the court of appeals dismissing a subsequent charge against Defendant for aggravated robbery in Weber County, holding that all provisions under Utah's Single Criminal Episode Statute, Utah Code 76-1-401 to -403, were met.
The State prosecuted Defendant in Weber County for aggravated robbery after he had already been convicted of theft by receiving in Utah County for conduct arising under the same criminal episode. After the court of appeals dismissed the Weber County charge the State appealed, arguing that Defendant's convictions were not part of a single criminal episode and that the Single Criminal Episode Statute did not apply because the district court in Utah County did not have jurisdiction to hear both offenses. The Supreme Court affirmed, holding that the conviction of Defendant in Utah County for theft by receiving barred the State's subsequent prosecution of Defendant in Weber County for aggravated robbery.
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