State v. Garcia (1983)
In State v. Garcia, 663 P.2d 60, 65 (Utah 1983), the Court concluded that an attempt to escape arrest was an admission by conduct. After a police officer observed the defendant dispose of a body, the officer apprehended the defendant. Id. at 62, 65.
The defendant then said "'I will kill you,' to a passerby whom the officer had asked to summon help." Id. at 65.
The Court concluded that the defendant's statement was an "attempt to counter the officer's effort to obtain help in arresting him," and that such an attempt to escape arrest constituted an admission by conduct. Id.