## Facts

- Hisae Wood was stabbed to death between approximately 3:00 a.m. and 4:00 a.m. on April 27, 1984; her body had 107 stab wounds.
- Earlier that night, Fred W. Standiford and Joey Granato were in Standiford’s garage painting a Jeep and twice went to Wood’s residence to buy cocaine, returning to use it and continue painting.
- Standiford left the garage around 4:00 a.m., purportedly to buy cigarettes, and returned after a longer-than-expected absence; he later produced additional cocaine and denied returning to Wood’s residence.
- After police questioned Standiford, he told Granato they were “both in trouble” and urged Granato to tell police they had not left the garage; Granato instead provided police a statement about their movements and cocaine purchases.
- Police searched Standiford’s house and garage and found evidence linking him to the homicide.
- Standiford confessed to killing Wood but claimed self-defense, stating Wood confronted him with a gun and he grabbed a kitchen knife and began “swinging” it.
- After the killing, Standiford washed his hands and the knife, wiped fingerprints, turned off lights, took cocaine and the gun, disposed of the knife, stopped at a convenience store, changed clothes, and hid evidence.

## Issues

1. Whether Utah’s second-degree murder statute required proof of “malice aforethought” as an element and whether the jury had to be instructed on that concept.
2. Whether the statutory phrase “depraved indifference to human life” was unconstitutionally vague or inadequately explained to the jury.
3. Whether the jury instructions on lesser-included offenses (including manslaughter) and self-defense were legally sufficient.
4. Whether evidentiary and procedural rulings denied Standiford a fair trial.

## Decision

- The Utah Supreme Court affirmed Standiford’s conviction for second-degree murder.
- The court held that “malice aforethought” was not a separate, required element of second-degree murder under Utah’s statutory scheme, and the trial court did not err by omitting such an instruction.
- The court rejected vagueness and instructional challenges to “depraved indifference to human life,” concluding the statutory language provided adequate notice and standards.
- The court concluded the evidence—particularly the 107 stab wounds and post-homicide concealment—supported the jury’s rejection of self-defense and supported the mens rea required for second-degree murder.
- The court found no reversible error in the remaining instructional, evidentiary, or procedural claims.

## Legal Principles

- When a legislature defines homicide offenses by statute, courts apply the statute’s specified mental states; common-law terms such as “malice aforethought” are not additional elements unless the statute makes them so.
- “Depraved indifference to human life” is a constitutionally permissible mens rea formulation when read in context and conveyed through instructions that track the statutory standard.
- Second-degree murder may be distinguished from manslaughter by the degree and character of culpability: intentional killing or extremely reckless conduct showing an indifference to human life versus lesser forms of recklessness or killings mitigated by provocation or comparable circumstances.
- A jury may reject self-defense based on the nature of the assault and post-incident conduct, and an appellate court will generally defer to the jury’s credibility determinations when the evidence supports the verdict.

## Conclusion

The Utah Supreme Court upheld Standiford’s second-degree murder conviction, clarifying that Utah law did not require a separate “malice aforethought” instruction and that the statute’s “depraved indifference to human life” standard was valid and supported by the evidence.


State v. Standiford, 769 P.2d 254 (Utah 1988)