State v. Anderson
In State v. Anderson, 929 P.2d 1107 (Utah 1996), the Court considered the case of a defendant who had severed contact with his own attorney and with the prosecution. Anderson, 929 P.2d at 1110.
Citing several cases involving wrongdoing or misconduct on the part of absent defendants, the court reasoned "that in some circumstances, a defendant's absence from the jurisdiction can occasion the loss of a criminal appeal right" and "the 'defendant must bear the consequences of his illegal acts.'" Id. at 1111 (quoting State v. Verikokides, 925 P.2d 1255, 1258 (Utah 1996)).