State v. Sosa-Hurtado, 2019 UT 65 (Oct. 31, 2019)

Defendant shot and killed a shopkeeper’s son within a few feet of the shopkeeper—close enough that the shopkeeper “felt the air displaced by the bullets.”  A jury convicted defendant of aggravated murder based on the “great risk of death” aggravator.  Affirming, the supreme court clarified that “the risk of death need not result directly from the precise act that caused the victim’s death” for the aggravator to apply, but instead “may be satisfied if the great risk of death was created within a ‘brief span of time’ of the act causing the murder and the acts together ‘formed a concatenating series of events.’”  Id. ¶ 2.