In the case, State v. Young, 2026 UT App64, the Utah Court of Appeals issued a detailed opinion that reinforces a critical principle in criminal law: if there is evidence supporting a defense, the jury must be instructed on it. The case also draws a clear line between defense of habitation and self-defense, two doctrines that are often confused.

The Encounter That Led to Charges

The case began when a contractor hired by a power company came to Young’s home to replace a power meter. The contractor wore a company hat and badge, but he was not in full uniform. His truck, which had a company logo, was parked out of view.

Young became suspicious. He had recently had his meter replaced. He also believed the contractor had been walking around his yard in a way that raised concern. When the contractor said he was there to change the meter, Young questioned him.

Young called the power company. The employee he spoke with confirmed that crews were working in the area but could not verify that anyone had been sent to Young’s home. The employee suggested that Young ask the contractor for his supervisor’s name.

At that point, Young retrieved a shotgun from inside his home and returned to the door. The parties later disputed whether Young pointed the shotgun. According to Young, he did not. According to the contractor, he did.

Young asked the contractor for his supervisor’s name. The contractor gave the correct answer. The encounter ended without violence.

Law enforcement later investigated, and the State charged Young with aggravated assault.

What Happened at Trial

At trial, Young asked the court to instruct the jury on defense of habitation. He also initially raised self-defense. The district court declined to give either instruction.

The court reasoned that no reasonable person could believe that the contractor was attempting a violent or felony entry into the home. As a result, the jury was instructed only on the elements of aggravated assault.

The jury convicted Young.

The Legal Question on Appeal

On appeal, the key issue was not whether Young was guilty. Instead, the question was:

Should the jury have been allowed to consider whether Young’s actions were legally justified?

Under Utah law, a defendant is entitled to a jury instruction on an affirmative defense if there is any reasonable evidentiary basis for it. Importantly, courts must evaluate that question by viewing the evidence in the light most favorable to the defense.

The Court’s Analysis: Two Levels of Defense of Habitation

The Court of Appeals clarified that Utah’s defense of habitation statute includes two distinct levels of protection.

1. Baseline Defense (Non-Deadly Force)

The first level allows a person to use force—short of deadly force—if they reasonably believe it is necessary to prevent or stop an unlawful entry into the home.

Applying that standard, the court focused on Young’s version of events. Under that view:

Young believed the contractor was trespassing,
He believed the contractor might be impersonating a utility worker,
The contractor refused to leave, and
The power company could not confirm the contractor’s identity.

The court also emphasized that, for purposes of the instruction, it had to assume that Young did not point the shotgun, but only held it.

Given those facts, the court concluded that a jury could find that Young reasonably believed it was necessary to hold the shotgun while continuing the interaction at his back door to prevent an unlawful entry into his home.

Because that conclusion was reasonably supported by the evidence, Young was entitled to an instruction on the baseline defense of habitation.

2. Heightened Defense (Deadly Force)

The second level applies when force is intended or likely to cause death or serious bodily injury. This requires additional proof, such as:

A violent or stealthy attempt to enter the home, or
A reasonable belief that a felony is about to occur inside the home.

The court agreed with the district court that this higher standard was not met. Even under Young’s account:

The contractor was unarmed,
He made no threats, and
He did not attempt to force entry.

As a result, Young was not entitled to a heightened defense instruction.

Why the Error Required Reversal

The Court of Appeals did not stop at identifying error. It also addressed whether the error mattered.

It did.

At trial, Young’s defense was that he acted reasonably to protect his home. However, without a defense-of-habitation instruction, the jury had no legal framework to evaluate that claim.

Once the jury found that Young had made a threat accompanied by force, its analysis effectively ended. The jury was never asked to decide whether that conduct was justified.

The court explained that this removed the legal foundation for Young’s defense. Given the relatively limited and disputed evidence—especially on whether the shotgun was pointed—the court concluded that there was a reasonable likelihood the outcome could have been different.

That was enough to reverse the conviction.

Self-Defense: A Different Standard

The court also addressed Young’s claim that his attorney was ineffective for not securing a self-defense instruction.

That argument failed.

Self-defense requires a reasonable belief that another person is about to use imminent unlawful force. The court found no evidence to support that element. Even under Young’s testimony:

The contractor had no weapon,
He made no threats, and
He did not attempt to use force.

Because there was no evidentiary basis for self-defense, counsel was not ineffective for failing to pursue it.

Key Takeaways for Trial Practice

This decision offers several important lessons:

Low threshold for instructions: If there is any reasonable evidence supporting a defense, the instruction must be given.
Defense-friendly view of facts: Courts must evaluate the request from the defendant’s perspective, not by weighing credibility.
Different defenses require different proof: Defense of habitation focuses on preventing unlawful entry, while self-defense requires imminent harm.
Instructions shape outcomes: Without the proper instruction, a viable defense may never reach the jury in a meaningful way.

Conclusion

State v. Young is not just about one homeowner and one encounter. It is about the role of the jury.

When the evidence supports a defense, the jury must be allowed to consider it. By failing to give the defense-of-habitation instruction, the trial court prevented that from happening.

The Court of Appeals corrected that error and sent the case back for a new trial.