State v. Garcia (2001)
In State v. Garcia, 2001 UT App 19, 18 P.3d 1123, 1128-29 (Utah Ct. App. 2001) a Utah appellate court found plain error where the court gave an instruction that may have led the jury to believe that the defendant bore the burden of proving he was acting in self-defense. The defendant shot the victim when he thought the victim was reaching for a gun.
In considering whether the defendant was prejudiced, the court concluded that "had the burden of proof of self-defense been adequately explained to the jury, it is reasonably likely that the jury could have entertained a reasonable doubt as to whether Garcia acted in self-defense, thus requiring acquittal." Id. at 1129.