State v. Stewart, 2014 UT App 112 (May 22, 2014) 

A man with a knack for “obtaining” vehicles without paying for them was convicted of aggravated robbery and theft by receiving stolen property in connection with two vehicles in his collection. The first was a car he obtained from a rental company in Florida in 2007, which he used as his personal car for several years until he had put approximately 100,000 miles on it. The second was a BMW that he obtained after a test drive with a salesman from the dealership, when he dropped the salesman off on the side of the freeway after showing him his gun. The Utah Court of Appeals affirmed the aggravated robbery conviction but remanded the theft conviction for a new trial because the State supported that charge with hearsay from the rental company’s manager and from the National Crime Information Center database.