Pursuant to rule 24(j), Utah Rules of Appellate Procedure, I submit the following supplemental authority in support of the State's argument in the above case. In State v. Wilson, 710 P.2d 801 (Utah 1985), the Utah Supreme Court affirmed an order arresting judgment based upon insufficient evidence that a crime was committed. This holding supports the State's position in footnote 1 of the brief that State v. Owens, 753 P.2d 976, 978 (Utah Ct. App. 1988), should not be followed.
Public record document (some rights may be reserved).
Legal Brief, Utah v. Workman, No. 900103 (Utah Court of Appeals, 1990).