SCM NEWS & OPINIONS

State v. Peraza, 2018 UT App 68 (Apr. 18, 2018).

In this criminal case, the State attempted to offer an expert opinion without providing an expert report, as required by Utah Code § 77-17-13.  Reversing the convictions, the court of appeals held that the trial court abused its discretion by admitting the expert testimony offered by the State, because the State failed to provide the report and, as a result, the district court lacked sufficient information to make a determination as to admissibility under Rule 702.