Utah teenager Meagan Grunwald was improperly convicted of aggravated murder in the 2014 death of a sheriff’s deputy and she is entitled to a new trial, the Utah Supreme Court ruled Friday.
Justices pointed to mistakes in the instructions given to jurors about Grunwald’s potential criminal liability as an accomplice to her boyfriend, who had fired at officers out of the truck she was driving. While the Utah Court of Appeals had previously ruled that the mistakes did not prejudice the jury against her, the justices disagreed, according to the decision released Friday.
“It is reasonably probable that the jury would not have convicted Ms. Grunwald of aggravated murder absent the jury instruction errors,” Chief Justice Matthew B. Durrant wrote.
Associate Chief Justice Thomas R. Lee dissented, saying he disagreed that a “properly-instructed jury would have acquitted Grunwald of the charge against her.”
The court’s decision reversed Grunwald’s conviction in the death of Utah County Sheriff’s Sgt. Cory Wride and ordered a new trial.
After hearing about the Supreme Court’s decision, Wride’s widow, Nannette Wride-Zeeman, told The Tribune, “I am completely disappointed and disgusted with our judicial system."
“Our justice system, the one my husband worked for his whole life, who we’ve dedicated our lives to, that he died for, is letting him down," she said.
Brent Jex, president of the Utah Fraternal Order of Police, also was outraged, calling the decision a “huge injustice” for Wride and Deputy Greg Sherwood, who was severely wounded that day.
“The Utah FOP is calling for Utah County prosecutor David Leavitt to commit to trying this case again,” Jex said. “Cory Wride and Greg Sherwood deserve nothing less than the full weight of the Utah County Attorney’s Office behind securing a second conviction.”
Grunwald was 17 years old on Jan. 30, 2014, when she drove her truck through two counties as her boyfriend, Jose Angel Garcia-Jauregui, 27, fired a gun out the back window at police officers and other motorists.
Wride was killed that day, while Sherwood was wounded. Garcia-Jauregui was fatally wounded later that day during a shootout with officers in Nephi.
Grunwald, now 23, was convicted of 11 felonies. Her attorney appealed seven of them based on issues with the jury instructions.
In March 2018, the Utah Court of Appeals had ruled that five of those convictions should be overturned and remanded for a new trial, but it upheld her convictions for aggravated murder and aggravated robbery.
Attorneys for Grunwald appealed the aggravated murder decision to the state Supreme Court, leading to Friday’s ruling. Grunwald’s attorney Doug Thompson said he was thrilled with the Friday ruling and that it was “a long time coming.”
He added, however, “I’m very sensitive to the idea that this is emotional for all the parties involved and that it’s not an easy case to have to retry. But there’s such a fundamental problem with the way the jury instructions framed the case, that it’s a case where a retrial is necessary."
In the Court of Appeals decision, the appellate judges wrote that the jury instructions used at trial misstated the law of accomplice liability, which is the statute that allows accomplices to be charged and held equally accountable for crimes even if they are committed by another person.
Durrant wrote the jury instructions erred in three ways. First, it allowed the jury to consider whether Grunwald was being reckless that day (as opposed to intending to help Garcia or knowingly helping him). Then, it let jurors make a conviction based on Grunwald helping Garcia at all — even if that help was not directly related to the murder. Last, it allowed a conviction if Grunwald knew Garcia’s actions were “reasonably certain” to result in aggravated murder. It should have only found her guilty if she “knowingly” acted to help Garcia commit the murder.
Specifically, the instructions told jurors they could convict Grunwald if she “intentionally aided Mr. Garcia, who committed the crime.” However, it should have said she was guilty if “she intentionally aided Mr. Garcia to commit the crime," Durrant wrote.
While the Court of Appeals noted this error, they said it was inconsequential since Grunwald knew she was helping Garcia commit a crime. He told her of his criminal intent, according to the appellate court decision, by saying he was going to “buck [the officer] in the f------ head."
Yet, Durrant writes it’s unclear that Grunwald knew what “buck” meant in this context. She testified she did not. There is also evidence that Grunwald has a learning disability, and her attorneys had said she was “easily intimidated and was under a lot of stress at the time.”
Durrant also says the Court of Appeals was wrong in ruling as if the timeline of events in the shooting was undisputed.
In one telling of events, he writes, Garcia said he would “buck” the officer before Grunwald shifted her truck into gear and then spent several minutes preparing for the slaying before firing. In another version, he made the comment long after she shifted into gear and began shooting immediately after saying it.
“Under the latter scenario, Ms. Grunwald would have had little time to process or otherwise react to the comment, and none of Ms. Grunwald’s actions, which allegedly aided Mr. Garcia, could have been done with knowledge of what Mr. Garcia intended to do," Durrant wrote.
Durrant noted that while the justices concluded a jury could have — without the faulty jury instruction — acquitted Grunwald of murder, “this conclusion should not be misinterpreted as a finding that Ms. Grunwald is, in fact, not guilty.”
Wride-Zeeman said she doesn’t know how she’ll weather another trial, but she said she will. And she is confident prosecutors will again make a strong case that Grunwald is guilty in her late husband’s death, and that a jury will side with them.
“She will be guilty every single time," Wride-Zeeman said. “So let her stand trial and let her be guilty before everyone in Utah. She’s guilty."
