was anachronistic and was not adequate in protecting an innocent person in the event of a false confession. In its place, the Court introduced the "trustworthiness standard," which takes into account the circumstances of the confession while deciding its usability in court. Ellis v. Estate of Ellis, 169 P.3d 441 (Utah 2007) The newlyweds Steven and Aimee Ellis were driving in Shelley, Idaho on January 2, 2001 when Steven Ellis lost control of his car. He swerved into oncoming traffic and crashed into a truck, killing himself instantly. Aimee Ellis sustained severe injuries (including significant head trauma) and was rushed to the hospital. In 2005, Mrs. Ellis filed a claim against her husband's estate for Mr. Ellis's negligence. The Third District Court dismissed her claim on the grounds of interspousal immunity, the principle under which "the husband and wife are one person in law: that is, the very being or legal existence of the woman is suspended during the marriage, or at least is incorporated and consolidated into that of the husband." Mrs. Ellis appealed to the Utah Supreme Court. Upon reviewing the case, the Court decided in a unanimous vote to overturn the district court's decision, holding that "the common-law doctrine of interspousal immunity has been abrogated in Utah with respect to all claims," thus laying to rest the doctrine of interspousal immunity in Utah. Burke v. Lewis, 122 P.3d 533, 535 (Utah 2005) Athan Montgomery sustained serious brain damage at the time of his birth. The birth injury allegedly occurred as a result of attending physician Dr. Gregory Drezga's actions and substandard care during Athan's delivery. Heidi Judd, Montgomery's mother, filed a medical malpractice suit against Drezga, but Drezga had left Utah by the time the suit was filed. Drezga's malpractice insurer would normally have held been responsible for Drezga's legal defense, but they requested that they be removed from responsibility on the grounds that Drezga was not present in Utah to assist in his own defense. Judd, hoping to ensure that she would still be able to collect any judgment against Drezga, filed a motion requesting the district court to appoint legal counsel to represent Drezga's interests. The district court appointed attorney Paul C. Burke to represent Drezga. Burke appealed the appointment order, but it was dismissed. Burke then filed a Petition for Extraordinary Relief to the Utah Supreme Court because of "his inability to gain speedy