Justia Utah Supreme Court Opinion Summaries

In 2001, Morris Mullins, then seventeen, killed a seventy-eight-year-old widow, Amy Davis, in her home. He was charged as an adult with rape and aggravated murder. Mullins pled guilty to aggravated murder in exchange for the State dropping the rape charge and not seeking the death penalty. He was sentenced to life without parole (LWOP). At sentencing, the court considered evidence of Mullins's dysfunctional upbringing and psychological evaluations but ultimately imposed a juvenile life without parole (JLWOP) sentence.Mullins later challenged his sentence as unconstitutional, citing the Eighth Amendment and the Utah Constitution. In 2013, he filed a pro se motion to correct an illegal sentence under rule 22(e) of the Utah Rules of Criminal Procedure, arguing that his sentence was unconstitutional under Miller v. Alabama, which held that mandatory JLWOP for juveniles violated the Eighth Amendment. The district court denied his motion in 2016, and Mullins's appeal was delayed until 2020 due to ineffective assistance of counsel.The Utah Supreme Court reviewed the case, focusing on whether Mullins's JLWOP sentence was constitutional. The court held that the sentencing judge's comments suggested ambiguity about Mullins's capacity for change, which undermined confidence in the appropriateness of the JLWOP sentence. The court vacated Mullins's sentence and remanded for resentencing, emphasizing the need to consider Mullins's youth and potential for rehabilitation in light of Miller and its progeny. The court did not find the sentencing statute unconstitutionally vague or the JLWOP categorically unconstitutional but required a more thorough consideration of Mullins's youth and potential for change. View "State v. Mullins" on Justia Law

In 2016, Chad Hintze, a registered sex offender, visited a public park, violating his sex offender registry conditions. He was charged with a class A misdemeanor in 2018 while serving a prison sentence for a separate offense. However, the State did not notify Hintze of the charge until March 2020, when he was being considered for parole on the separate offense. The State began prosecuting the misdemeanor in June 2020 after Hintze requested a hearing.Hintze moved to dismiss the charge, claiming his Sixth Amendment right to a speedy trial was violated due to the State's two-year delay, which he argued prejudiced his parole chances. The Third District Court, Salt Lake County, disagreed, finding Hintze's prejudice claim speculative and determining that his speedy trial right was not violated based on the Barker v. Wingo framework. Hintze entered a conditional guilty plea and appealed.The Utah Court of Appeals, in a divided decision, reversed the district court's ruling, concluding that the Barker factors favored Hintze and required dismissal of the case on Sixth Amendment grounds. The State then petitioned the Utah Supreme Court for certiorari review.The Utah Supreme Court reviewed the case and concluded that although the two-year delay was significant, the Barker factors, when appropriately weighed, did not establish a violation of Hintze’s speedy trial right. The court found that the delay, caused by the State's negligence, was not extraordinary, and Hintze's claim of prejudice was speculative. Consequently, the court reversed the court of appeals' decision, reinstated Hintze’s conviction, and remanded the case to the court of appeals for further proceedings on Hintze’s motion to suppress. View "State v. Hintze" on Justia Law

Deon Jennings was arrested and charged with first-degree murder after stabbing Willie Houston twice in the back, resulting in Houston's death. Jennings argued at a bail hearing that he should be released on bail because the State had not presented substantial evidence to support the charge, claiming he did not intend to injure Houston and acted in self-defense. The district court rejected Jennings' arguments and ordered him held without bail. Jennings appealed, and the Utah Court of Appeals affirmed the district court's decision.The Utah Court of Appeals reviewed the case and concluded that the State had presented substantial evidence of the requisite mens rea for first-degree murder. The court noted that Jennings' own statements and the nature of Houston's injuries provided a reasonable basis for a jury to conclude that Jennings intended to cause serious bodily injury to Houston. The court also addressed the issue of self-defense, assuming for the sake of argument that the State had the burden to disprove self-defense at the bail hearing. The court found that the State had met this burden, as Jennings' statements indicated he did not feel threatened by Houston, and the evidence suggested that any belief Jennings might have had that Houston posed an imminent threat was not reasonable.The Utah Supreme Court reviewed the case and affirmed the court of appeals' decision. The Supreme Court held that the State presented substantial evidence of Jennings' intent to cause serious bodily injury to Houston, as required for a first-degree murder charge. The court also agreed that the State had presented substantial evidence disproving Jennings' claim of self-defense, noting that Jennings' own statements and the circumstances of the altercation did not support a reasonable belief that he was acting in self-defense. View "State v. Jennings" on Justia Law

Stephen Rippey pled guilty to one count of aggravated sexual abuse of a child and one count of object rape of a child. He was sentenced to two concurrent prison terms of fifteen years to life. Ten years after his conviction, a district court reinstated Rippey’s time to file a direct appeal. On appeal, Rippey challenged several aspects of his plea, conviction, and sentence, leading the Supreme Court of Utah to address whether the Plea Withdrawal Statute (PWS) is constitutional.The Third District Court in West Jordan initially accepted Rippey’s guilty plea after a colloquy and a signed plea form. Rippey did not move to withdraw his plea before sentencing. He later filed a pro se petition for post-conviction relief under the Post-Conviction Remedies Act (PCRA), listing seventeen claims. The district court dismissed eight claims as frivolous and the remaining claims for failure to state a claim. Rippey’s requests for appointed counsel were denied. The Utah Court of Appeals upheld the district court’s dismissal, concluding that Rippey’s claims were unpreserved except for ineffective assistance of counsel, which lacked merit.The Supreme Court of Utah reviewed the constitutionality of the PWS, specifically subsections (2)(b) and (2)(c). The court held that subsection (2)(b)’s preservation rule and the corresponding waiver in subsection (2)(c) violate the separation of powers under the Utah Constitution. These provisions were deemed procedural, not substantive, and thus beyond the legislature’s authority to enact. The court concluded that the PWS does not bar Rippey’s challenge to his guilty plea, and his appeal is now governed by standard rules of preservation. The court instructed the parties to brief the merits of Rippey’s challenges under these standards. View "State v. Rippey" on Justia Law

The case involves William Torres, who was convicted by a jury of one count of rape. The district court had concerns about the performance of Torres's trial counsel and appointed post-trial counsel to investigate potential errors. Torres, through his new counsel, moved for a new trial, arguing ineffective assistance of counsel under the Strickland v. Washington standard, which requires showing that counsel's performance was deficient and that the deficient performance prejudiced the defense.The district court granted Torres a new trial, finding that his trial counsel's performance was objectively unreasonable in several respects and that these errors cumulatively prejudiced Torres. The court concluded that Torres received ineffective assistance of counsel and ordered a new trial under rule 24(a) of the Utah Rules of Criminal Procedure.The State appealed, and the Utah Court of Appeals reversed the district court's decision. The court of appeals reviewed the district court's determination of ineffective assistance of counsel for correctness, as per existing precedent. The court concluded that Torres had failed to show that his trial counsel's performance was both deficient and prejudicial under Strickland.On certiorari, Torres argued that the court of appeals applied the wrong standard of review and that the district court's ruling should be reviewed for abuse of discretion. The Utah Supreme Court rejected this argument, affirming that legal decisions embedded in a district court's new trial ruling are reviewed for correctness. The court also declined to overrule its precedent in Menzies v. Galetka, which holds that ineffective assistance is a law-like mixed question reviewed for correctness.The Utah Supreme Court agreed with the court of appeals that Torres had not established a reasonable probability of a different result at trial absent counsel's alleged errors. Consequently, the court affirmed the decision of the court of appeals, reversing the district court's grant of a new trial and remanding for sentencing. View "State v. Torres-Orellana" on Justia Law

Randi Mariani crashed her motor scooter and sustained a serious injury during a driving skills test, which she was taking to obtain a motorcycle endorsement to her driver license. Following the crash, the Utah Department of Public Safety-Driver License Division (DLD) denied Mariani’s application for the endorsement. Mariani sued the DLD for negligently causing her injury. The district court granted summary judgment to the DLD based on governmental immunity, and the court of appeals affirmed.The district court concluded that the DLD was immune from Mariani’s suit under the Governmental Immunity Act of Utah (GIA), reasoning that Mariani’s injury arose out of the administration of her motorcycle skills test, which was part of the licensing process. The court of appeals agreed, stating that Mariani’s injury was at least incident to the licensing approval process.The Utah Supreme Court reviewed the case to determine whether the court of appeals erred in affirming the district court’s decision. The Supreme Court focused on the specific language of the GIA’s licensing exception, which provides immunity for injuries that arise out of or in connection with the denial of a license. The Court concluded that the relevant conduct was the denial of the motorcycle endorsement, not the licensing process itself. The Court further determined that there was no causal relationship between the denial of the license and Mariani’s injury, as the injury occurred before the denial. Therefore, the licensing exception did not apply, and the DLD was not immune from Mariani’s suit. The Supreme Court reversed the court of appeals’ decision and remanded the case for further proceedings. View "Mariani v. Driver License Division" on Justia Law

A customer, Davie Montes, purchased a used car from National Buick GMC (National) and signed two agreements: a Purchase Agreement and an Arbitration Agreement. The Purchase Agreement included an integration clause stating it was the complete and exclusive statement of terms. The Arbitration Agreement, which did not have an integration clause, covered disputes related to the purchase or financing of the vehicle. After experiencing issues with the car, Montes sued National, which then moved to compel arbitration based on the Arbitration Agreement.The Fourth District Court in Provo denied National's motion, ruling that the Purchase Agreement's integration clause made it the sole agreement between the parties. The Utah Court of Appeals affirmed this decision, interpreting Utah precedent to mean that the integration clause precluded consideration of the Arbitration Agreement.The Supreme Court of the State of Utah reviewed the case and reversed the lower courts' decisions. The Supreme Court held that contemporaneous, executed agreements related to the same transaction should be construed together, even if one contains an integration clause. The court found that the Purchase Agreement and the Arbitration Agreement were part of the same transaction and should be considered together. The case was remanded for further proceedings consistent with this opinion. View "Montes v. National Buick GMC" on Justia Law

Erik Schnibbe, an attorney, worked at the law firm of Magleby, Cataxinos, and Greenwood. After a client of the firm won a large damages award, the firm paid Schnibbe $1 million for his share of the contingency fee via direct deposit. Schnibbe believed he was promised a greater share and kept the $1 million. Years later, after leaving the firm, he sued for the additional money he claimed he was owed.The Defendants, including the firm and two of its attorneys, moved for summary judgment, arguing that Schnibbe had accepted the $1 million as full settlement of his share of the contingency fee, thus barring his claims under the doctrine of accord and satisfaction. The district court agreed and granted summary judgment to the Defendants.The Utah Court of Appeals affirmed the district court's decision, concluding that all three elements of accord and satisfaction were met: an unliquidated claim or bona fide dispute over the amount due, a payment offered as full settlement of the entire dispute, and acceptance of the payment as full settlement of the dispute. The court focused on the acceptance element, determining that Schnibbe's retention of the $1 million for four years without attempting to return it or registering a protest constituted acceptance of the payment as full settlement.The Utah Supreme Court reviewed the case on certiorari. The court agreed with the lower courts that Schnibbe's conduct indicated acceptance of the payment as full settlement. The court clarified that acceptance could be inferred from the totality of the circumstances, including the creditor's retention of the funds, even if the payment was received passively via direct deposit. The court held that Schnibbe's knowing retention of the $1 million for several years, without attempting to return it, constituted acceptance of the proposed accord as a matter of law. The court affirmed the decision of the court of appeals. View "Magleby v. Schnibbe" on Justia Law

In 2015, Michael Jerry Felts pled guilty to assaulting a police officer and failing to stop at the command of police. The State sought restitution for damage to a police vehicle during the pursuit. The district court referred the restitution question to the Board of Pardons and Parole, which ordered Felts to pay $9,415.28 in June 2021. Felts objected, arguing that insurance had already covered the damage. After legislative amendments in July 2021 removed the Board's authority to issue restitution orders and allowed for judicial review of such orders, Felts contended that the district court could now review the Board's order.The district court held that it lacked jurisdiction to review the Board's restitution order. The Utah Court of Appeals affirmed, stating that the legislative amendments did not retroactively grant district courts the authority to review Board-issued restitution orders. The court of appeals concluded that the amendments were intended to clarify and consolidate restitution authority in district courts moving forward, not to provide retroactive judicial review of past Board decisions.The Utah Supreme Court reviewed the case and affirmed the court of appeals' decision. The Supreme Court held that the legislative amendments did not grant district courts the authority to review restitution orders issued by the Board of Pardons and Parole. The court emphasized that the plain language of the amendments did not support Felts's interpretation and that the removal of the prohibition on judicial review of Board restitution orders was for clarity and consistency, not an independent grant of judicial review. The court also noted that Felts could seek relief through an extraordinary writ under rule 65B of the Utah Rules of Civil Procedure, but he had not pursued that option. View "State v. Felts" on Justia Law

The case involves a dispute over a proposed constitutional amendment in Utah, referred to as Amendment D. The amendment, proposed by the Utah State Legislature, seeks to change the state constitution in three significant ways: specifying that the right to alter or reform the government can only be exercised through constitutional processes, banning foreign influence in the initiative and referendum processes, and granting the Legislature unlimited power to amend or repeal any law passed by a citizen initiative. The controversy centers on whether the amendment was properly submitted to voters and whether it was published as required by the Utah Constitution.The Third Judicial District Court in Salt Lake County reviewed the case and found that the Legislature had not complied with the constitutional requirements for submitting and publishing the proposed amendment. The court ruled that the ballot title for Amendment D was misleading and did not accurately reflect the substance of the amendment, thus failing to meet the Submission Clause of the Utah Constitution. Additionally, the court found that the Legislature did not cause the amendment to be published in newspapers across the state for two months preceding the election, as required by the Publication Clause. Consequently, the district court issued a preliminary injunction declaring Amendment D void and ordered that any votes cast on the amendment not be counted.The Utah Supreme Court reviewed the district court's decision and affirmed the preliminary injunction. The Supreme Court agreed that the ballot title was misleading and did not provide voters with a clear understanding of what they were voting for or against, thus violating the Submission Clause. The Court also held that the Legislature failed to comply with the Publication Clause by not ensuring continuous publication of the amendment's text in newspapers for the required two-month period. The Supreme Court concluded that the district court did not abuse its discretion in finding that the balance of harms and the public interest favored issuing the preliminary injunction. As a result, Amendment D was declared void, and any votes cast on it will have no effect. View "League of Women Voters v. Utah State Legislature" on Justia Law