The Utah Supreme Court addressed a significant criminal procedure question in *State v. Jennings*, ruling on whether defendants can obtain pretrial hearings for self-defense justification claims before facing trial for murder charges.
Deon Andre Jennings is charged with the murder of Willie Houston and is awaiting trial in the Third District Court in Salt Lake County. Jennings moved for a pretrial justification hearing to adjudicate his claim that he was justified in killing Houston because he was defending himself.
The case centers on Utah's Pretrial Justification Statute, Utah Code section 76-2-309, which provides a mechanism for criminal defendants to have justification defenses determined by the district court before trial. The statute requires that upon a defendant's motion, the court "shall hear evidence" on the asserted justification and "shall determine as a matter of fact and law whether the defendant was justified in the use or threatened use of force."
The statute establishes a specific burden-shifting framework for these pretrial hearings. First, the defendant must "make a prima facie claim of justification." This procedural requirement places an initial burden on defendants to present sufficient evidence to support their self-defense claims before the court will proceed with a full evidentiary hearing.
Justice Petersen authored the opinion of the Court, joined by Justice Hagen and Justice Pohlman. Chief Justice Durrant authored a separate opinion concurring in part, dissenting in part, and concurring in the judgment, joined by Associate Chief Justice Pearce. The divided nature of the court's response suggests the complexity of the legal issues involved in pretrial justification proceedings.
The case originated from the Third District Court in Salt Lake County, where Judge Coral Sanchez presided over the lower court proceedings. The Supreme Court heard oral arguments on October 25, 2024, and filed its opinion on November 28, 2025.
The State of Utah was represented by Derek E. Brown, Attorney General, and Andrew F. Peterson, Deputy Solicitor General. Jennings was represented by Erick Grange of Salt Lake City.
This case represents an important development in Utah criminal law, particularly regarding the procedural rights of defendants who claim self-defense in homicide cases. The pretrial justification statute allows defendants to potentially resolve self-defense claims before trial, which could result in dismissal of charges if the court finds the defendant was justified in using force.
The burden-shifting framework established by the statute creates a two-step process. After the defendant establishes a prima facie case of justification, the burden shifts to the prosecution to prove beyond a reasonable doubt that the defendant was not justified in using force. This procedural mechanism allows courts to evaluate self-defense claims on their merits before subjecting defendants to full criminal trials.
Pretrial justification hearings serve several important functions in the criminal justice system. They can potentially save judicial resources by resolving cases before trial when defendants can demonstrate clear justification for their actions. They also provide defendants with an opportunity to present their self-defense claims in a focused hearing designed specifically to evaluate justification issues.
The statute's requirement that courts "shall hear evidence" creates a mandatory framework for these proceedings when properly invoked by defendants. This mandatory language ensures that defendants who can establish prima facie justification claims receive full consideration of their defenses before trial.
The case also highlights the intersection between substantive self-defense law and criminal procedure. While self-defense has long been recognized as a justification for the use of force, the procedural mechanisms for adjudicating these claims continue to evolve. Utah's pretrial justification statute represents a proactive approach to resolving these issues early in the criminal process.
The opinion's treatment of the burden-shifting framework will likely influence how defense attorneys and prosecutors approach pretrial justification proceedings in Utah courts. The specific requirements for establishing a prima facie case of justification will guide defense strategy in future cases involving self-defense claims.
For defendants facing serious charges like murder, the pretrial justification process provides a critical opportunity to avoid trial if they can demonstrate their actions were legally justified. The statute's framework ensures that these determinations are made through proper evidentiary proceedings with appropriate burden allocations between the parties.
The *Jennings* case will serve as important precedent for Utah courts handling similar pretrial justification motions in homicide and other serious felony cases involving self-defense claims. The Supreme Court's interpretation of the statute's requirements will guide trial courts in conducting these specialized hearings and evaluating justification evidence.