State v. Lawrence 120 Utah 323, 234 P.2d 600 (1951)
Lawrence was suspected of stealing a car. He was arrested
and charged with Grand Larceny.
At the time, Grand Larceny meant stealing something worth
more than $50.
At trial, the prosecution failed to offer any evidence as
to the value of the stolen car. At the conclusion of evidence, Lawrence made a motion for a directed verdict because there was no evidence in the record
that Lawrence stole something worth more than $50.
The Trial Judge denied the motion, and issued an
instruction to the jury that they could assume that the value of the car
was more than $50.
That's known as judicial notice.
The Trial Court found Lawrence guilty of Grand Larceny.
The Utah Supreme Court reversed and remanded for a new
The Utah Supreme Court noted that the State had a burden
of proving every essential element of the crime.
The Court found that the value of the car was a fact that
could have been determined by the jury.
The judge should have just told the jury that one
element of the case was that the car needed to be worth more than $50.
If the fact was so beyond doubt as the judge thought, then no reasonable
jury would have thought that the car was worth less than $50.
In a dissent it was argued that the value of the car was a
well enough established fact that the judge could just tell the jury to
assume the value of the car.
The case was decided under the common law. Now it would
be covered by FRE 201.