review of the appointment order through normal appellate channels." The issue that the Utah Supreme Court was to decide was whether the district court acted outside of its discretion in appointing Burke to act in Drezga's defense absent an express statutory authorizing to do so. In a unanimous decision, the Court decided it was within the district court's discretion to appoint counsel in Drezga's absence, but because of the multitude of factors influencing the district court's decisions, the Supreme Court limited its decision to the unique facts in the case and declined to adopt a general rule that "appointment of counsel is generally an acceptable practice whenever an innocent third party may be subject to adverse repercussions if a judgment is entered against an absent civil litigant." State v. Levin, 144 P.3d 1096 (Utah 2006) Ralph Levin was convicted in a Utah trial court for possession of marijuana. He appealed the decision to the Utah Court of Appeals on the grounds that the trial court hadn't suppressed condemning statements he had made prior to being read his Miranda Rights. Levin claimed that the trial court had incorrectly concluded that he had not been subjected to custodial interrogation (in which case, he would not have needed to be told his Miranda Rights). The Utah Court of Appeals upheld the trial court's decision. It concluded that while Levin had been subjected to interrogation, he was not in custody at the time of interrogation, thereby applying "a deferential 'abuse of discretion' standard of review to the trial court's determination that Levin was not 'in custody.'" Levin petitioned the Utah Supreme Court for a writ of certiorari, arguing that the Court of Appeals had inappropriately applied an abuse of discretion standard in its review of the trial court's decision. The Utah Supreme Court agreed to hear the appeal and, in a unanimous decision, determined the trial court erroneously applied the more deferential "abuse of discretion" standard in reviewing whether Levin should have been given his Miranda rights. The Court remanded the case to the Court of Appeals, holding that "custodial interrogation determinations should be reviewed for correctness." Conatser v. Johnson, 194 P.3d 897 (Utah 2008) In June 2000, the Conatser family was fishing in the Weber River when they unintentionally floated into the Johnsons' property. They touched the riverbed four separate times, after which the Johnsons requested that they take their boat from the