State v. Sanchez, 2018 UT 31 (July 5, 2018)

In rejecting an appeal for a murder conviction, the court held that the subjective element for demonstrating extreme emotional distress under the special mitigation statute required a showing that (1) the defendant was “exposed to extremely unusual and overwhelming stress,” (2) that he had an “extreme emotional reaction” to the stress such that his capacity for reason was overcome, (3) that the emotional distress was not the result of a mental illness, and (4) that the distress was not “substantially caused by his own conduct.”