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.