The Utah Supreme Court has ruled in a high-profile case involving Kain Blackwing, a man accused of orchestrating an attempted murder plot from jail. The court’s decision allows prosecutors to present evidence of Blackwing’s alleged sexual assault of a minor and his controlling relationship with the women he lived with. This ruling reverses a lower court’s decision to exclude much of this evidence, which the Supreme Court deemed crucial to understanding the context of the alleged conspiracy.
The case centers around Blackwing, who is charged with soliciting, conspiring to commit, and attempting to commit the murder of a fourteen-year-old girl, C.G., and her parents. According to the prosecution, Blackwing sought to silence C.G. to prevent her from testifying against him in a separate rape case. Blackwing allegedly directed three women with whom he had a polygamous relationship to carry out the murder.
Blackwing’s attorneys argued to exclude evidence of his past actions, including the rape case involving C.G., his conviction for raping one of his alleged co-conspirators (Tina), and details of his relationship with the three women. They argued that this evidence was irrelevant or unfairly prejudicial, potentially influencing the jury to make a decision based on Blackwing’s character rather than the specific charges. The district court initially sided with Blackwing, excluding much of the evidence.
The Supreme Court, however, has taken a different view. The court’s opinion, authored by Justice Hagen, clarifies the rules regarding the admissibility of “other acts” evidence, specifically under Utah Rule of Evidence 404(b). This rule generally prohibits the introduction of evidence of a person’s prior bad acts to prove that they acted in conformity with that character on a specific occasion. However, the court has made it clear that evidence that is “intrinsic” to the charged crime is not subject to this rule.
Defining “Intrinsic” Evidence
The Supreme Court provided a clear definition of “intrinsic” evidence, which is key to understanding its ruling. The court stated that evidence is intrinsic when there is a “direct relationship between the act and the charged crime.” Essentially, the acts must be an “integral and natural part of the . . . circumstances surrounding the offense” or “directly connected to the factual circumstances of the crime.”
The court rejected Blackwing’s argument that the definition of intrinsic evidence should be limited to actions that are necessary to prove the charged offense or that occur at the same time as the alleged crime. The court found that such a narrow interpretation would unduly restrict the prosecution’s ability to present a complete picture of the events leading up to the alleged conspiracy.
The C.G. Case and Its Relevance
The Supreme Court determined that the details of the sexual assault case involving C.G. were indeed “intrinsic” to the charges of solicitation, conspiracy, and attempted murder. The court reasoned that the alleged rape of C.G. was the very reason for the murder plot. Blackwing allegedly wanted C.G. silenced to avoid a conviction. The court found that this evidence was essential to understanding Blackwing’s motive and the context of the alleged conspiracy.
The court also addressed the lower court’s decision to exclude the specific details of the C.G. case. The Supreme Court found that the lower court had applied too strict a standard for relevance. The court emphasized that evidence is relevant if it has “any tendency to make a fact more or less probable” to a fact of consequence in the case. The court explained that the details of the C.G. case, including the severity of the alleged crime and C.G.’s role as the victim, were relevant to the State’s theory of the case.
The court stated that excluding this evidence would leave a “chronological or conceptual void in the story” and impair the jury’s ability to understand the State’s case. The court noted that it’s important for the jury to have the whole picture and that excluding information would cause the jury to question the motive to commit murder.
The Role of Rule 403: Weighing Prejudice
The Supreme Court also addressed the lower court’s decision to exclude the evidence under Rule 403, which allows a court to exclude relevant evidence if its probative value is substantially outweighed by the risk of unfair prejudice. The Supreme Court found that the lower court had undervalued the probative value of the evidence and overstated the risk of prejudice.
The court acknowledged that evidence of a sex crime involving a child could be inflammatory. However, the court stated that in this case, the probative value of the evidence was high because it directly related to Blackwing’s motive to commit murder. The court emphasized that the evidence was not unfairly prejudicial because it was being used to explain the circumstances surrounding the alleged crime.
The Tina Case and Relationship with Co-Conspirators
The court addressed the evidence regarding Blackwing’s relationship with Tina, one of the alleged co-conspirators. The court upheld the lower court’s decision to exclude evidence of Blackwing’s *conviction* for the crimes against Tina, as it stated that it did not have any independent probative value. The jury will weigh the evidence and assess credibility, so evidence of a conviction would encourage the jury to abdicate its fact-finding responsibility and would be overly prejudicial.
However, the Supreme Court reversed the exclusion of evidence regarding Blackwing’s relationship with Tina, Raven, and Theresa. The court found that the details of Blackwing’s relationship with the women, including his alleged manipulation, coercion, and control, were intrinsic to the charges. The court reasoned that the nature of these relationships was crucial to understanding how Blackwing could have convinced the women to participate in the murder plot.
The court found that the State must prove, among other things, that Blackwing and the women had agreed to carry out the crime and that Blackwing solicited the women to commit the crime. The court stated that the relationship between Blackwing and the women was key to the conspiracy and solicitation charges. The court stated that the evidence of Blackwing’s alleged dominance over the women shows why he selected them, issued an edict in coded language, trusted them to remain silent, and knew that they would carry out his plan.
The Supreme Court concluded that the lower court had applied the wrong legal standards in excluding the evidence. The court reversed the lower court’s decision to exclude the evidence regarding Blackwing’s sexual assault of C.G. and his relationship with the other women. The court remanded the case for trial or further proceedings consistent with its opinion. The district court retains discretion to rule on rule 403 objections raised at trial, but the blanket exclusion of all specific acts tending to show Blackwing’s dominance over his alleged co-conspirators resulted from an incorrect application of the rules.
This ruling is a significant victory for the prosecution, as it will allow them to present a more complete picture of the events leading up to the alleged murder plot. The court’s decision also underscores the importance of understanding the context of a crime when evaluating evidence.