State v. Sisneros, 2020 UT App 60 (Apr. 9, 2020)
The court of appeals reversed denial of a motion to dismiss and held that two cases – one in Weber County and one in Utah County – were part of the same criminal episode. Sisneros stole a car in Weber County and while driving away, hit the car owner’s father, and ultimately abandoned the car in Utah County. He was charged in Utah County for theft by receiving stolen property, and Weber County charged him with aggravated robbery. Following a plea in Utah County, Sisneros moved to dismiss the Weber County case, which the district court denied. In reversing, the court of appeals held, “there was not a distinct difference in time between the two offenses at issue” with Sisneros committing both the aggravated robbery and theft by receiving in Weber County.