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Attorney Profile Photo of M. David Steffensen

A Return to Chaos or a Reasonable Compromise:

This article explores the effect of Utah Code Ann. § 75-2-503, commonly referred to as the Harmless Error Statute, on estate planning and probate litigation for both attorneys and the public at large.

State v. Valdez, 2021 UT App 13 (Feb. 11, 2021)

Reversing convictions for kidnapping, robbery, and aggravated assault, the court of appeals held that the defendant’s right against self-incrimination under the Fifth Amendment was violated when the prosecution presented evidence that he refused to provide the swipe code to his…