The Utah Court of Appeals has ruled that a jury relied on incorrect instructions when it convicted a Utah teen in a 2014 crime spree in which one peace officer was killed and another was wounded.
But while the appeals court has remanded Meagan Grunwald’s case back for a new trial, the judges ruled that the woman’s convictions of aggravated murder — for the death of Utah County Sheriff’s Sgt. Cory Wride — and a charge of aggravated robbery for carjacking a vehicle will remain.
This means that Grunwald, who is now 21, will continue serving consecutive prison terms of 25-years-to-life and five-years-to-life on the two counts. Utah County prosecutors will decide whether to re-try the case on the five counts that were remanded — unless the case is appealed again to the Utah Supreme Court.
Grunwald was 17 years old when, on Jan. 30, 2014, she drove her truck through two counties as her boyfriend, 27-year-old Jose Angel Garcia-Jauregui, fired a gun out the back window at police officers and passing motorists.
| Courtesy Utah County Sheriff Sergeant Cory Wride, age 44, Utah County Sheriff's Office
Wride was killed that day, while Deputy Greg Sherwood was severely wounded. Garcia-Jauregui was fatally wounded later that day during a shootout with officers in Nephi.
A jury in 2015 found Grunwald criminally culpable for the crimes, and convicted her of first-degree felony aggravated murder and 10 other crimes. In a Thursday opinion, the justices 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.
Grunwald’s trial attorneys did not object to the language, and that amounted to ineffective assistance of counsel, the judges ruled.
Grunwald’s appellate attorneys had argued that the errors in the wording of the jury instructions distorted the state law and “made it easier for the state to obtain convictions against Meagan as an accomplice.”
But while there was an error, the appeals court found that there was “no reasonable probability” that the mistake would have affected the jury’s verdict on the aggravated murder and aggravated robbery counts.
“However, there is a reasonable probability that Grunwald may have secured an acquittal on the remaining counts had the jury been correctly instructed on the law,” the opinion reads.
The state statute says that a person is guilty as an accomplice if he or she “solicits, requests, commands, encourages or intentionally aids another person to engage in conduct which constitutes an offense.”
Grunwald and Garcia-Jauregui were on the side of the road in Utah County on the day of the shooting when Wride pulled up to see if they needed help. Wanted on an outstanding warrant, Garcia-Jauregui gave the 44-year-old officer a false name and then killed him as he sat in his vehicle checking their licenses.
At trial, Grunwald testified that Garcia-Jauregui threatened to kill her and her family if she didn’t do as he said.
But prosecutors argued Grunwald was a willing participant in Wride’s death. They used police dashboard-camera recordings and witness testimony as evidence to counter Grunwald’s claims that she was threatened to act as her boyfriend’s getaway driver.
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