State v. Lawrence
120 Utah 323, 234 P.2d 600 (1951)

  • Lawrence was suspected of stealing a car.  He was arrested and charged with Grand Larceny.
    • At the time, Grand Larceny meant stealing something worth more than $50.
  • At trial, the prosecution failed to offer any evidence as to the value of the stolen car.  At the conclusion of evidence, Lawrence made a motion for a directed verdict because there was no evidence in the record that Lawrence stole something worth more than $50.
  • The Trial Judge denied the motion, and issued an instruction to the jury that they could assume that the value of the car was more than $50.
    • That’s known as judicial notice.
  • The Trial Court found Lawrence guilty of Grand Larceny.  He appealed.
  • The Utah Supreme Court reversed and remanded for a new trial.
    • The Utah Supreme Court noted that the State had a burden of proving every essential element of the crime.
    • The Court found that the value of the car was a fact that could have been determined by the jury.
      • The judge should have just told the jury that one element of the case was that the car needed to be worth more than $50.  If the fact was so beyond doubt as the judge thought, then no reasonable jury would have thought that the car was worth less than $50.
  • In a dissent it was argued that the value of the car was a well enough established fact that the judge could just tell the jury to assume the value of the car.
  • The case was decided under the common law.  Now it would be covered by FRE 201.