State v. Rushton, 2017 UT 21 (Apr. 7, 2017)

Utah Code § 76-1-401 prohibits the State from prosecuting a defendant in separate actions for conduct that may establish separate offenses under a single criminal episode.  The court adopted a totality of the circumstances test with enumerated factors to determine whether conduct aims at a single criminal objective.  Applying this new test, the court concluded that the petitioner’s wage and tax crimes did not have a single criminal objective.