Motive Theory

I. The State’s Motive Theory Collapses Under Its Own Witness

The State charged a political-expression victim-targeting enhancement. It alleges that Mr. Robinson intentionally selected Charlie Kirk because of Kirk’s political expression. The charging document further claims that Mr. Robinson’s mother described him as becoming more political, leaning left and becoming more interested in gay and transgender rights. Neither parent testified during this preliminary hearing. Source: atty.utahcounty.gov Instead, the State presented the recorded interview of Lance Twiggs, the person who lived with Mr. Robinson and was romantically involved with him. And what did the State’s own central witness say?

• Twiggs did not closely follow politics.
• Political discussions between the two were not consistent.
• Mr. Robinson sometimes mentioned things heard on the radio during his commute.
• The subjects were generally Trump or current policies.
• They did not really discuss gender-identity or LGBTQ-rights issues.

That is the witness the State says received his confession. That is the witness the State relies upon to explain the alleged Dremel request, the alleged note, the alleged messages and Mr. Robinson’s behavior after returning home. Most importantly, Twiggs said: “I personally had never heard him talk about Charlie Kirk before specifically.” Source: rev.com That is the witness who shared Mr. Robinson’s home.

The State wants this Court to leap from occasional comments about Trump and public policy to a meticulously planned political assassination. Its own witness did not build that bridge.

• an obsession with Charlie Kirk;
• repeated discussions about Charlie Kirk;
• escalating political rage;
• threats of political violence;
• fantasies about assassination;
• hatred consuming the household;
• or any demonstrated progression from political opinion to murder.

The State instead attempts to construct motive backward from the ammunition inscriptions and alleged messages: a cartridge contained political or cultural language; therefore the shooter was politically motivated. The rifle belonged to Mr. Robinson; therefore Mr. Robinson engraved the cartridges. Messages attributed to Mr. Robinson referenced hatred; therefore he authored the inscriptions and committed the shooting. Every part depends upon the next. That is circular reasoning — not independent proof of motive.

Twiggs knew where the household Dremel was. He testified that the apartment contained a common area where household tools were kept and that he directed Mr. Robinson to the Dremel’s location. That testimony establishes shared access to the tool. It does not establish who used it, when it was used, what it was used upon or who engraved the ammunition. Source: rev.com The State presented no eyewitness who saw Mr. Robinson engrave cartridges. It presented no forensic tool-mark comparison tying the lettering to that Dremel. It presented no video of the engraving. It presented no dated photograph showing Mr. Robinson performing it. It presented no recovered draft or plan independently connecting him to the inscriptions. The State has a motive allegation. Its closest witness did not corroborate the alleged obsession behind it.