State v. Lawrence 120 Utah 323, 234 P.2d 600 (1951) Lawrence was suspected of stealing a car.  He was arrested and charged with Grand Larceny. At the time, Grand Larceny meant stealing something worth more than $50. At trial, the prosecution failed to offer any evidence as to the value of the stolen car.  At the conclusion of evidence, Lawrence made a motion for a directed verdict because there was no evidence in the record that Lawrence stole something worth more than $50. The Trial Judge denied the motion, and issued an instruction to the jury that they could assume that the value of the car was more than $50. That's known as judicial notice. The Trial Court found Lawrence guilty of Grand Larceny.  He appealed. The Utah Supreme Court reversed and remanded for a new trial. The Utah Supreme Court noted that the State had a burden of proving every essential element of the crime. The Court found that the value of the car was a fact that could have been determined by the jury. The judge should have just told the jury that one element of the case was that the car needed to be worth more than $50.  If the fact was so beyond doubt as the judge thought, then no reasonable jury would have thought that the car was worth less than $50. In a dissent it was argued that the value of the car was a well enough established fact that the judge could just tell the jury to assume the value of the car. The case was decided under the common law.  Now it would be covered by FRE 201.