State v. Archuleta

In State v. Archuleta, 850 P.2d 1232 (Utah 1993), the defendant argued that if any of the criminal acts inflicted on the victim were completed before the intent to commit the homicide was formed, then those offenses cannot be aggravating circumstances. The Court disagreed and held that as long as there is "no break in the chain of events from the inception of the felony to the time of the homicide, we treat the two events as part of one continuous transaction."