Facts:
Deon Jennings was charged with first-degree murder after stabbing Willie Houston twice in the back, resulting in Houston’s death. Jennings argued at a bail hearing that he should be released because the State had not presented “substantial evidence to support the charge,” as required by Article I, Section 8 of the Utah Constitution and Utah Code § 77-20-201. He claimed he acted in self-defense during an altercation inside an apartment that Houston shared with Jennings’ aunt. Jennings did not have permission to be there. The State relied on Jennings’ own statements and a detective’s reenactment of his actions. Jennings claimed Houston was on top of him during a fight but also said he was not injured and did not feel threatened. The district court denied bail. The court of appeals affirmed. Jennings sought certiorari review.
Issue:
- Did the State present substantial evidence of the requisite mens rea for first-degree murder at the bail hearing?
- Assuming self-defense was properly raised, did the State present substantial evidence disproving that Jennings acted in self-defense?
Rule:
Under Article I, Section 8 of the Utah Constitution and Utah Code § 77-20-201(1)(c), bail may be denied for certain felonies if (1) there is substantial evidence to support the charge and (2) the court finds by clear and convincing evidence that the defendant is a danger to others or a flight risk.
“Substantial evidence” means evidence that, if believed by a jury, would provide a reasonable basis for a guilty verdict beyond a reasonable doubt.
To disprove self-defense, the State must show that the defendant did not reasonably believe force was necessary to prevent imminent unlawful force (Utah Code § 76-2-402).
Application:
- Mens Rea: Jennings admitted to grabbing an object (possibly a screwdriver) and striking Houston in the back twice. His reenactment showed deliberate motion and force. The depth of the stab wounds (three and five inches) indicated intent to cause serious bodily injury—satisfying the required mental State under § 76-5-203(2)(b).
- Self-Defense: Even if the State had the burden to disprove self-defense at a bail hearing, it met that burden. Jennings stated he was not injured, did not feel threatened, and Houston never struck him. Houston was unarmed and had asked Jennings to leave the apartment. The court found the use of deadly force was disproportionate and not based on a reasonable belief of imminent danger. After fleeing the scene, not calling 911, and stating he didn’t care, Jennings’ behavior afterward undermined a self-defense claim.
Conclusion:
The Utah Supreme Court affirmed the court of appeals. The State presented substantial evidence of both the required mental State for first-degree murder and evidence disproving self-defense. Jennings’ continued detention without bail was upheld.