Justia Utah Supreme Court Opinion Summaries

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Utah Code prohibits subsequent state prosecution of the “same offense” for which defendant was convicted in federal court. Robertson was convicted by the federal government for possession of child pornography. The state subsequently charged him with 20 counts of sexual exploitation of a minor based on the same conduct. Robertson cited Utah Code section 76-1-404: [i]f a defendant‘s conduct establishes the commission of one or more offenses within the concurrent jurisdiction of this state and of another jurisdiction, federal or state, the prosecution in the other jurisdiction is a bar to a subsequent prosecution in this state if . . . the former prosecution resulted in an acquittal, conviction, or termination . . . and the subsequent prosecution is for the same offense. The Utah Supreme Court’s interpretation of section 404, in State v. Franklin, permitted subsequent prosecutions by different sovereigns, for the same offense. The court of appeals affirmed Robertson‘s convictions. The supreme court reversed, overruling Franklin and holding that the statute’s use of the phrase “same offense” is an express rejection of the dual sovereignty doctrine. Section 404 requires courts to employ only the Blockburger-Sosa test: two offenses are not the same if each requires proof of an element that the other does not. Section 404, properly interpreted, prohibits the state from prosecuting Robertson. View "State v. Robertson" on Justia Law
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The Supreme Court reversed the district court’s order granting Defendant’s motion to suppress the evidence obtained after a law enforcement officer stopped a vehicle for a traffic violation and searched Defendant, a passenger, incident to his arrest on an outstanding arrest warrant. The district court had concluded that the trooper had violated Defendant’s Fourth Amendment rights when he asked to see Defendant’s identification and ran a warrants check without reasonable suspicion that Defendant had committed or was about to commit a crime. The Supreme Court disagreed, holding that the officer’s seconds-long extension of the lawful traffic stop to request Defendant’s identification did not unreasonably prolong the detention and that officer safety concerns justified the “negligibly burdensome extension of the traffic stop[.]” View "State v. Martinez" on Justia Law

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The Supreme Court held that, under Utah Code 31A-22-305.3, a underinsured motorist (UIM) insurer must fully compensate its insured within its policy limits but only for damages in excess of what was paid by workers’ compensation so as to avoid an inappropriate double recovery. Danny Rutherford, who was injured when the work van he was driving was hit by another vehicle, sought double recovery from his employer’s workers’ compensation insurer and Truck Insurance Exchange, which provided Rutherford’s employer with underinsured motorist coverage. The district court granted summary judgment for Rutherford. In light of its holding, the Supreme Court reversed. View "Truck Insurance Exchange v. Rutherford" on Justia Law
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Defendant was convicted of possessing a shank in prison. Defendant appealed, arguing (1) the trial court erred in denying his motion to dismiss because the State lost or destroyed a video recording of the discovery of the shank, and (2) his counsel was ineffective in stipulating to the due process analysis applicable to claims regarding evidence destroyed or lost by the State. The Supreme Court affirmed, holding (1) under the due process analysis set forth in State v. Tiedemann, Defendant’s due process rights were not violated; and (2) Defendant’s counsel did not provide ineffective assistance. View "State v. Mohamud" on Justia Law

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Defendant entered a conditional guilty plea to one count of assault by a prisoner. Defendant appealed, arguing (1) the district court erred in denying her motion to dismiss because a video recording of the assault was lost or destroyed by the State, and this loss of evidence violated her due process rights; and (2) the district court applied the wrong legal standard to her claim by imposing a threshold requirement that she demonstrate a reasonable probability that the evidence would have been exculpatory. The Supreme Court reversed, holding (1) the district court correctly recognized that the due process analysis set forth in State v. Tiedemann encompasses a threshold reasonable probability requirement; (2) the court erred by applying an overly stringent interpretation of what constitutes a “reasonable probability” and in ruling that Defendant failed to satisfy the threshold requirement; (3) the court erred in its application of the factors set forth in Tiedemann; and (4) dismissal was the appropriate remedy for the negligence of the State in failing to preserve the footage and the crucial role that footage would have played in this case. View "State v. DeJesus" on Justia Law
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Defendant was charged with the alleged rape or object rape of four women. During Defendant’s trial for the rape of K.S., the State moved to introduce the testimony of the other women, including A.P., under Utah R. Evid. 404(b) and the doctrine of chances. The district court granted the motion. Thereafter, Defendant entered a conditional guilty plea to the rapes of two of the four women. The court of appeals reversed in part, concluding (1) State v. Verde’s four foundational requirements displaced the factors set forth in State v. Shickles for purposes of a Utah R. Evid. 403 balancing test; and (2) the district court erred in its decision to admit the testimony of A.P. The Supreme Court affirmed but under different reasoning, holding (1) in applying Rule 403, a court is bound by the language of the rule but is not required to consider any set of elements or factors; and (2) the district court in this case did not abuse its discretion in failing to consider the Verde requirements but did abuse its discretion by mechanically applying the Shickles factors to assess the probative value of the State’s Rule 404(b) evidence. View "State v. Lowther" on Justia Law
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The mandatory joinder statute, Utah Code 76-1-401, prohibits the State from prosecuting a defendant in separate actions for conduct that may establish separate offenses under a “single criminal episode.” A “single criminal episode” is defined as “all conduct which is closely related in time and is incident to an attempt or an accomplishment of a single criminal objective.” Petitioner filed a motion to dismiss the wage crimes prosecution as barred by the mandatory joinder statute, arguing that the State violated section 76-1-401 by prosecuting him from 2011 to 2012 for wage crimes after having prosecuted and convicted him in 2009 and 2010 for tax crimes. Petitioner argued that the conduct underlying both prosecutions was part of a single criminal episode because it was closely related in time and incident to an attempt of accomplishment of the single criminal objective of misappropriation of money in his business setting. The district court denied the motion, and the court of appeals affirmed. The Supreme Court affirmed, holding that Defendant’s conduct did not have a single criminal objective and thus did not constitute a single criminal episode. View "State v. Rushton" on Justia Law
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This case involved a claim for restitution by the victim of a sex crime committed by Defendant. The State alleged that Defendant’s crimes led to the victim’s depression, which impacted her ability to work and required counseling. The district court ordered Defendant to pay $12,934 in lost income in addition to restitution of the costs of the victim’s counseling. On appeal, Defendant challenged the lost income award, arguing that lost income is not available under the Crime Victims Restitution Act unless “the offense resulted in bodily injury to a victim.” The court of appeals affirmed. The Supreme Court reversed, holding that restitution for lost income was not available in this case because there was no allegation that Defendant’s offense “resulted in bodily injury” to the victim. View "State v. Wadsworth" on Justia Law
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Defendant was charged and tried on four counts of theft and one count of attempted theft. After a jury trial, all jurors found Defendant guilty on all five counts. Defendant challenged his conviction under the Unanimous Verdict Clause of the Utah Constitution, alleging that there was lack of unanimity as to alternative factual theories advanced by the prosecution in support of some of the theft counts against him. Alternatively, Defendant alleged two other sets of trial errors as grounds for reversal. The Supreme Court affirmed, holding (1) precedent does not support the requirement of unanimity or sufficiency of the evidence for alternative, exemplary means of committing a crime, and the Utah Constitution imposes no such requirement; (2) the evidence was sufficient to support the jury’s verdict; and (3) Defendant otherwise failed to identify a basis for reversal of his convictions. View "State v. Hummel" on Justia Law

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The administrator of the Utah Motor Vehicle Enforcement Division denied Tesla Motors UT, Inc., a wholly owned subsidiary of a motor vehicle manufacturer, an application for a license to sell new motor vehicles, determining that the application implicated both the Motor Vehicle Business Regulation Act (Licensing Act) and the New Automobile Franchise Act (Franchise Act). The Tax Commission affirmed. The Supreme Court affirmed, holding that the Licensing Act and Franchise Act together prohibit a wholly owned subsidiary of a motor vehicle manufacturer from obtaining a license to sell the manufacturer’s new motor vehicles in stores in Utah, and the statutory scheme is constitutional. View "Tesla Motors UT, Inc. v. Utah Tax Commission" on Justia Law