Utah's high court rules man accused of killing cellmate would not qualify for reduced conviction

SALT LAKE CITY — A man accused of killing his cellmate has not convinced the Utah Supreme Court that he should be allowed to argue for a reduced conviction because he was experiencing a schizophrenic delusion at the time.

The opinion, written by Justice John Nielsen, reversed the decision made by the district court. It explained that if James Afuakimoana Tamoua hallucinated as he claimed, he would have a compulsion defense — which does not qualify as a justification defense under Utah's code. The judges determined a legal justification defense is required in Utah's laws for a defendant to qualify for a reduced homicide conviction.

In the ruling, the judges said on Sept. 21, 2019, Tamoua heard a voice while in his cell at the Utah State Prison saying "kill your cellmate, or I'll kill you and your family," and he felt a sensation in his leg that convinced him that the dark entity which spoke was proving it could carry out the threat.

He then strangled his cellmate, Reo Guy Watts, 38, and then pressed the emergency button to alert the guards, telling them when they arrived "I think I killed him, cuff me up," the ruling said. It also states Tamoua later told investigators that he killed the man to save his life.

In November 2022, Tamoua filed a notice of intent to pursue a special mitigation, based on his delusion, meaning he wanted the jurors, in addition to considering whether he is guilty, to consider whether his conviction should be reduced; for example, from murder to manslaughter based on his justification.

Prosecutors argued compulsion is not a defense in the justification section of Utah code, the ruling said, and asked the court not to allow him to purse that question, but the 3rd District Court ruled that Tamoua could argue for the special mitigation.

The judge, James Blanch, found on April 10, 2024 that the phase "legal justification" could have a colloquial meaning and, if the term is ambiguous, then Tamoua should receive the benefit of the ambiguity in this situation.

The case appeared before the Utah Supreme Court after prosecutors contested that decision, and the high court was tasked with determining the meaning of the phrase "legal justification" in Utah's law. It found although there is not a specific definition, the statute Tamoua wanted to take advantage of cited the legal justification code, which does narrow the definition.

"The district court functionally gave it a broader and more colloquial meaning — that is, anything in the law that nullifies a person's responsibility for a crime. But the Legislature has defined justification more particularly than that," the ruling said.

The high court also found that Tamoua had not asserted a legal justification that does fit Utah's code, but said it would not comment on whether Tamoua may have other defenses that he could use to try to reduce a conviction in the case.

Tamoua's case is now back in the 3rd District Court, where he has a hearing on Friday. He is charged with murder, a first-degree felony.

He was in prison after resolving multiple cases in February 2019, including convictions in federal and state court for robbing a convenience store at gunpoint, convictions for stabbing an inmate with a pencil and breaking a fire sprinkler in his cell at the Davis County Jail and for failing to stop for police in 2017.

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