UTAH SUPREME COURT
MARCH 5, 2014
S.J. QUINNEY COLLEGE OF LAW, UNIVERSITY OF UTAH
Case Summary — Salt Lake City v. Miles
Wade Miles attempted to board a light rail train at a downtown Salt Lake City
stop. The train operator prevented Miles from boarding because Miles was trying to
board with a shopping cart. Thinking that Miles was intoxicated, the train operator
radioed for assistance from the field supervisor on patrol that night. The supervisor
arrived and tried to get Miles to move to the sidewalk. After a short exchange, Miles
became verbally abusive and began using profanities. The supervisor threatened to call
the police. Miles then made a statement about a knife and a gun. In his witness
statement, the supervisor wrote that Miles said that “if” he had a gun or a knife he
would kill the supervisor. At trial, the supervisor testified that Miles said that “he had a
knife and a gun” and would kill the supervisor if he did not get away from him.
A police officer arrived and administered a field sobriety test, which Miles failed.
The officer arrested Miles for threatening the supervisor and for intoxication and
searched Miles’s shopping cart incident to the arrest. He found a “jacket [and] in that
jacket pocket was a folding knife.” When the officer asked Miles about the knife, Miles
“said he forgot that he had it.” En route to the jail, Miles told the officer that “he had
used it for camping.” The knife's blade is approximately 3 ½ inches long and the handle
approximately 3 ½ to 4 inches long. It features a thumb stud to allow the user to swing
the blade open with one hand. A portion of the blade, about 1 ½ inches, is serrated.
Miles was charged with criminal trespass; threats against life or property;
intoxication; and purchase, transfer, possession or use of a dangerous weapon by a
restricted person. Utah Code section 76-10-503(3) provides: “A Category II restricted
person who purchases, transfers, possesses, uses, or has under the person's custody or
control . . . any dangerous weapon other than a firearm is guilty of a class A
misdemeanor.” Utah Code section 76-10-501(6) defines a dangerous weapon as “an item
that in the manner of its use or intended use is capable of causing death or serious
bodily injury. . . . The following factors shall be used in determining whether a knife, or
another item, object, or thing not commonly known as a dangerous weapon is a
dangerous weapon: (i) the character of the instrument, object, or thing; (ii) the character
of the wound produced, if any; (iii) the manner in which the instrument, object, or thing
was used; and (iv) the other lawful purposes for which the instrument, object, or thing
may be used.” Miles is a Category II restricted person based on a prior conviction.
After a one-day jury trial, Miles was acquitted of criminal trespass, threats
against life or property, and intoxication but convicted of possession of a dangerous
weapon by a restricted person. Miles appealed his conviction to the Utah Court of
Appeals, arguing, among other things, that the evidence did not support the jury’s
implicit finding that the knife was a dangerous weapon as defined by Utah Code
section 76-10-501(6). In a 2-1 opinion, the court of appeals affirmed. The Utah Supreme
Court granted certiorari of the following issue: “Whether the court of appeals erred in
holding there was sufficient evidence to support Petitioner’s conviction for violating
[the statute prohibiting possession of a dangerous weapon by a restricted person].”