## Facts

- Floyd Eugene Maestas and two accomplices agreed to rob the home of 72-year-old Donna Bott.
- The group entered Bott’s residence, and accomplice testimony described Maestas assaulting Bott while demanding money.
- Bott suffered severe injuries and died from the beating.
- The prosecution relied on accomplice testimony and corroborating physical and forensic evidence, including DNA and fingerprint evidence, as well as evidence of Maestas’s admissions and post-crime conduct.
- Maestas was charged with aggravated murder (based on killing during an aggravated burglary) and aggravated burglary.

## Issues

1. Whether trial errors in jury selection, evidentiary rulings, and prosecutorial argument required reversal of the convictions.
2. Whether the evidence, including accomplice testimony and forensic proof, was sufficient to support aggravated murder and aggravated burglary.
3. Whether Maestas proved intellectual disability under Utah’s statutory procedure implementing *Atkins v. Virginia*, thereby exempting him from the death penalty.
4. Whether penalty-phase evidence and instructions (including victim-impact evidence and aggravator/mitigator guidance) violated state or federal law.
5. Whether Utah’s death-penalty scheme was unconstitutional on Eighth Amendment or state-constitutional grounds, including claims of arbitrariness and discrimination.
6. Whether cumulative error warranted relief.

## Decision

- The Utah Supreme Court affirmed Maestas’s convictions for aggravated murder and aggravated burglary and affirmed the death sentence.
- The court held that the trial court did not commit reversible error in voir dire, juror rulings, evidentiary decisions, or handling of argument.
- The court held that accomplice testimony was sufficiently corroborated by independent evidence and that the evidence was sufficient when viewed in the light most favorable to the verdict.
- The court upheld admission of the State’s DNA and fingerprint evidence under Utah’s expert-evidence standards, treating defense critiques primarily as matters of weight for the jury.
- The court affirmed the trial court’s finding that Maestas failed to prove intellectual disability under Utah law and therefore was not exempt from capital punishment under *Atkins*.
- The court upheld penalty-phase rulings, including admission of victim-impact evidence within permissible bounds and jury guidance on aggravating and mitigating circumstances.
- The court rejected constitutional attacks on Utah’s capital-sentencing framework and denied relief under the cumulative-error doctrine.

## Legal Principles

- Appellate review of jury-selection and evidentiary rulings is deferential to the trial court; reversal requires a showing of abuse of discretion and prejudice.
- Accomplice testimony may support a conviction when corroborated by independent evidence tending to connect the defendant to the offense, and corroboration may be supplied by forensic and other circumstantial proof.
- Expert forensic evidence is admissible when the trial court, acting as gatekeeper, finds the methodology sufficiently reliable; competing critiques often affect weight rather than admissibility.
- Under Utah’s *Atkins* implementing statute, the defendant bears the burden to establish intellectual disability; trial-court fact findings on competing expert testimony are reviewed for clear error.
- Victim-impact evidence is generally admissible in capital sentencing if it does not encourage the jury to decide on arbitrary or inflammatory grounds and remains within the trial court’s discretion.
- Broad constitutional challenges to a death-penalty scheme, including claims based on generalized disparities, do not warrant relief without case-specific proof of unconstitutional operation.
- Cumulative-error relief is unavailable where the alleged errors are not errors or are harmless, and their combined effect does not undermine confidence in the verdict or sentence.

## Conclusion

The Utah Supreme Court affirmed Maestas’s capital convictions and death sentence, holding that the guilt and penalty proceedings were legally sound, that Maestas did not prove an *Atkins* exemption, and that Utah’s death-penalty framework and the trial court’s rulings did not violate constitutional or statutory requirements.


State v. Maestas, 299 P.3d 892 (Utah 2012)