2016 UT App 235

THE UTAH COURT OF APPEALS

STATE OF UTAH,

Appellee,

v.

AARON DAVID TRENT NEEDHAM,

Appellant.

Memorandum Decision

No. 20140483-CA

Filed December 8, 2016

Fifth District Court, St. George Department

The Honorable A. Lynn Payne

No. 101500067

Aaron David Trent Needham, Appellant Pro Se

Sean D. Reyes and Jeanne B. Inouye, Attorneys

for Appellee

JUDGE GREGORY K. ORME authored this Memorandum Decision, 

in which JUDGES MICHELE M. CHRISTIANSEN and DAVID N.

MORTENSEN concurred.

ORME, Judge:

¶1 Aaron David Trent Needham was convicted of eight 

counts of communications fraud and one count of pattern of 

unlawful activity. On appeal, he raises a number of challenges, 

none of which has merit and all of which may be dealt with 

summarily.

¶2 First, Needham argues that the trial court erred in 

denying his motion for a new trial because he was “denied his 

right to confront witnesses against him and his counsel provided 

ineffective assistance of counsel.” Even with the trial court

assuming that the standard governing absences from trials and 

sentencing also applied to absences from depositions, it

concluded that Needham’s absence from the deposition was 
State v. Needham

20140483-CA 2 2016 UT App 235

voluntary. As the State correctly notes, Needham “has not 

addressed, much less challenged,” whether his absence from the 

deposition was voluntary. Because Needham has failed to 

address “the basis of the [trial] court’s ruling, we reject this 

challenge.” See Golden Meadows Props., LC v. Strand, 2010 UT App 

257, ¶ 17, 241 P.3d 375.

¶3 Second, Needham contends that his conviction violates

the double jeopardy clauses of the United States and Utah 

constitutions. Needham claims that his rights were violated 

when the Utah Division of Occupational and Professional 

Licensing sanctioned him for engaging in unlicensed contracting

and, alternatively, when a civil suit was filed against him for 

breach of contract. While the argument may not have been 

preserved, and although Needham seems to suggest that failure 

to raise the issue was the product of ineffective assistance of 

counsel, neither possibility affects our ultimate resolution of the 

issue. The simple fact is that neither proceeding is criminal in 

nature, and, accordingly, there can be no Double Jeopardy 

problem. See Hudson v. United States, 522 U.S. 93, 99 (1997) 

(stating that the Double Jeopardy Clause protects “only against 

the imposition of multiple criminal punishments for the same

offense”) (emphasis in original).

¶4 Third, Needham alludes to other claimed errors in the 

proceedings below. The State is correct that these issues are 

inadequately briefed. See State v. Green, 2005 UT 9, ¶ 11, 108 P.3d 

710 (“A brief [that] does not fully identify, analyze, and cite its 

legal arguments may be ‘disregarded or stricken’ by the 

court[.]”) (quoting Utah R. App. P. 24); State v. Thomas, 961 P.2d 

299, 305 (Utah 1998) (stating that an issue is inadequately briefed 

“when the overall analysis of the issue is so lacking as to shift the 

burden of research and argument to the reviewing court”). In 

view of the inadequate briefing, we have no occasion to consider

these issues.

¶5 Affirmed.