Justia Utah Supreme Court Opinion Summaries

In 1985, Douglas Carter was convicted and sentenced to death for the murder of Eva Olesen in Provo, Utah. There was no physical evidence linking Carter to the crime scene, but he signed a confession, and two witnesses, Epifanio and Lucia Tovar, provided testimony corroborating aspects of his confession. Decades later, the Tovars signed declarations stating that the police had threatened them, pressured them to make untrue statements, and instructed them to lie at Carter’s trial about financial support they had received from the police. Based on these revelations, Carter petitioned for postconviction relief.The Fourth Judicial District Court held an evidentiary hearing and found that Carter’s trial and sentencing were tainted by serious misconduct by the lead prosecutor, the lead investigator, and another police officer. The court found that the police had suborned perjury, threatened the Tovars with deportation and separation from their son, and provided them with financial assistance, which they were instructed to lie about. The prosecutor did not disclose this information to the defense or correct the false testimony at trial.The Utah Supreme Court reviewed the case and agreed with the lower court’s findings. The court concluded that the State had violated Carter’s constitutional right to due process by suppressing evidence favorable to Carter and by failing to correct false testimony. The court determined that these violations prejudiced Carter at both the guilt and sentencing stages of his trial. The court affirmed the lower court’s decision to grant Carter’s petition for postconviction relief, vacate his conviction and sentence, and order a new trial. View "Carter v. State" on Justia Law

Kyli Jenae Labrum was charged with ten counts of rape and one count of forcible sexual abuse after allegedly engaging in a sexual relationship with T.S., a sixteen-year-old boy. The State's case relied on two theories of nonconsent: a special trust theory and an enticement theory. At the preliminary hearing, the stand-in prosecutor only argued the special trust theory, which the magistrate judge rejected, ruling that the State had not shown the relationship was nonconsensual. The State then moved to reduce the charges to a lesser offense but later decided to pursue the original charges, filing a motion for reconsideration and then refiling the charges with both theories of nonconsent.The magistrate judge denied the motion for reconsideration and dismissed the refiled charges, ruling that the State's actions were procedurally inappropriate and constitutionally barred under the Utah Constitution’s Due Process Clause. The State appealed, arguing that the magistrate erred in its determination.The Utah Supreme Court reviewed the case, clarifying the standard for refiling charges after a dismissal for insufficient evidence. The court held that the State must show that it did not act in bad faith or with intent to harass when refiling charges. The court vacated the magistrate's ruling and remanded the case for further proceedings under the clarified standard. The court instructed the lower court to determine whether the State acted in bad faith when it failed to argue the enticement theory at the first preliminary hearing and subsequently refiled the charges. If the State prevails, it may proceed with a second preliminary hearing on both theories of nonconsent. If Labrum prevails, the State may only proceed on the lesser charges. View "State v. Labrum" on Justia Law

The State of Utah charged Kouri Darden Richins with aggravated murder and other crimes. The case received significant media attention, with extensive coverage from various media outlets. The State and Richins jointly requested that jury selection be held in person and that the jury venire be expanded to include prospective jurors from both Summit and Salt Lake counties. The Third District Court has a standing order requiring virtual jury selection unless "extraordinary circumstances" are found. The Presiding Judge denied the request for in-person jury selection, stating that media attention did not constitute extraordinary circumstances. The Trial Judge initially granted the request to expand the jury venire but later reversed his decision.The Third District Court's Presiding Judge denied the request for in-person jury selection, concluding that the intense media attention did not constitute extraordinary circumstances. The Trial Judge initially approved the request to expand the jury venire but reversed his decision after the Presiding Judge's order, concluding that Utah law did not permit summoning jurors from multiple counties for one trial.The Supreme Court of the State of Utah reviewed the case. The court held that the Presiding Judge did not abuse her discretion in denying the request for in-person jury selection, as the decision was within the bounds of reasonability. The court also held that the Trial Judge correctly interpreted Utah law, which requires jurors to be selected from a single county. The court affirmed the decisions of both the Presiding Judge and the Trial Judge, concluding that the requests for in-person jury selection and an expanded jury venire were properly denied. View "State v. Richins" on Justia Law

The Division of Child and Family Services (DCFS) petitioned to terminate the parental rights of S.S. (Father) and J.S. (Mother) to their two children, D.S. and K.S. At the time, the children were removed from Mother’s custody, and Father was incarcerated. The children were placed with their paternal grandmother (Grandmother), who has cared for them since. The juvenile court terminated Mother’s parental rights and later terminated Father’s parental rights, concluding that it was necessary to promote the children’s best interests, which were best served by Grandmother adopting them.Father appealed the juvenile court’s decision, arguing that the children’s best interests could be equally served by a permanent custody and guardianship arrangement with Grandmother, allowing him to retain residual parental rights. The Utah Court of Appeals agreed with Father, finding that the juvenile court’s decision was against the clear weight of the evidence and that the reasons for terminating Father’s rights were insufficient. The court of appeals reversed the juvenile court’s order.The Office of the Guardian ad Litem (GAL) petitioned for certiorari, arguing that the court of appeals gave insufficient deference to the juvenile court’s best interest determination and misapplied the standard of review. The Supreme Court of Utah agreed with the GAL, stating that an appellate court may reverse a juvenile court’s best interest determination only if it is against the clear weight of the evidence. The Supreme Court concluded that the juvenile court’s best interest analysis was supported by the evidence and that the court of appeals erred in overturning it. Therefore, the Supreme Court reversed the decision of the court of appeals, upholding the termination of Father’s parental rights. View "In re D.S." on Justia Law

Seth Clark Jolley was charged with raping T.T. Before his trial, Jolley moved under rule 412 of the Utah Rules of Evidence to determine the admissibility of evidence that he and T.T. had previously engaged in other sexual conduct. Rule 412 generally prohibits the admissibility of a victim’s other sexual behavior but allows exceptions under certain circumstances, such as to prove consent. Jolley filed a motion describing the evidence he sought to admit, stating that either he or T.T. would be its source.The Fourth District Court in Juab County concluded that Jolley had met his burden under rule 412 and that the incidents he wanted to inquire about were proper questions for an in camera hearing. T.T. objected, arguing that Jolley could not use rule 412 to compel her to testify about her alleged sexual behavior at the hearing. The court disagreed and ordered T.T. to testify, reasoning that the purpose of the 412 hearing was to identify the evidence for presentation to a jury.The Supreme Court of the State of Utah reviewed the case and concluded that the district court erred in its interpretation of rule 412. The court held that a party seeking to admit evidence under a rule 412(b) exception cannot compel a victim to testify at a rule 412 hearing. The court emphasized that the purpose of the rule 412 hearing is to give the victim and parties a right to attend and be heard, not to compel the victim to provide testimony. Accordingly, the Supreme Court reversed the district court’s denial of T.T.’s motion to quash Jolley’s subpoena and remanded for further proceedings. View "State v. Jolley" on Justia Law

Quintin Grillone resigned from his position as a police officer in 2014 while under investigation for providing false information to a prosecutor regarding a traffic citation against his mother. The Peace Officer Standards and Training Division (POST) did not learn of the incident until 2019 when Grillone disclosed it in his application to join a new police department. Following an investigation, POST initiated disciplinary proceedings, and an administrative law judge found that Grillone's conduct constituted obstruction of justice. The POST Council then retroactively suspended Grillone’s certification for three years.Grillone sought judicial review by the Utah Court of Appeals, arguing that the disciplinary proceedings were time-barred by the four-year catch-all statute of limitations for civil actions under Utah Code § 78B-2-307(4). He contended that the statute governing POST disciplinary proceedings referred to them as “civil actions,” thus subjecting them to the civil statute of limitations. The court of appeals, however, held that civil statutes of limitation do not apply to administrative disciplinary proceedings absent specific legislative authority and found that the POST statute did not incorporate the civil statute of limitations.The Utah Supreme Court reviewed the case and affirmed the court of appeals' decision. The Supreme Court agreed that civil statutes of limitation are generally inapplicable to administrative disciplinary proceedings unless the legislature indicates otherwise. The Court concluded that the POST statute’s reference to “civil actions” was intended to distinguish POST proceedings from criminal actions, not to incorporate the civil statutes of limitation. Therefore, the disciplinary proceedings against Grillone were not time-barred, and the POST Council’s three-year suspension of his certification was upheld. View "Grillone v. Peace Officer Standards" on Justia Law

E.M., a fifteen-year-old, was arrested for allegedly killing S.A. and wounding four others in a racially motivated drive-by shooting. The State charged E.M. with multiple felonies, including murder, in juvenile court and sought to transfer the case to district court.The juvenile court held a preliminary hearing where eight witnesses testified. The court found probable cause that E.M. was a principal actor in the murder and analyzed whether retaining jurisdiction was contrary to the best interests of E.M. and the public. The court considered the seriousness of the crime, the aggressive and premeditated nature of the offense, E.M.'s traumatic background, lack of prior criminal record, and the likelihood of rehabilitation. The court noted E.M.'s difficult childhood, marked by extreme trauma, and his progress in detention but also highlighted incidents of racially motivated violence. Ultimately, the court concluded that transferring E.M. to district court was appropriate.The Utah Supreme Court reviewed whether the juvenile court abused its discretion in transferring E.M.'s case. The court emphasized that the Transfer Statute requires a holistic approach, considering all relevant circumstances surrounding the qualifying offense. The court found that the juvenile court appropriately considered the context of the crime, including non-qualifying offenses, to assess the seriousness and premeditated nature of the offense. The court also held that the juvenile court did not err in weighing E.M.'s trauma history as a factor that could impact the likelihood of rehabilitation.The Utah Supreme Court upheld the juvenile court's decision, finding no abuse of discretion in the transfer of E.M.'s case to district court, concluding that it was in the best interests of both E.M. and the public. View "In re E.M." on Justia Law

Haylee Hinton was injured in a car accident caused by another motorist running a red light. She initially sought compensation from her employer’s workers’ compensation insurer and later settled with the motorist’s insurance carrier. Hinton then filed a claim for underinsured motorist benefits with Midwest Family Mutual Insurance, her underinsured motorist coverage provider, and submitted the claim to arbitration as permitted by Utah law.Midwest sought a declaratory judgment from the district court to limit the categories of damages Hinton could recover in arbitration, citing Utah Code section 31A-22-305.3(4)(c)(i), which excludes benefits paid or payable under the Workers’ Compensation Act from underinsured motorist coverage. The district court interpreted the statute to mean that past and future medical expenses and two-thirds of lost wages were payable under workers’ compensation and ruled that Hinton could not recover these categories of damages from Midwest.Hinton petitioned for interlocutory review, arguing that the district court lacked jurisdiction and misinterpreted the statute. The Utah Supreme Court found that the district court had jurisdiction but misinterpreted the statute. The court concluded that “payable” means benefits that can or may be paid to a specific claimant in a particular case, not just categories of damages generally available under workers’ compensation. The court vacated the district court’s order and remanded the matter for further proceedings to determine what benefits remain payable to Hinton under the Workers’ Compensation Act. View "Hinton v. Midwest Family Mutual Insurance" on Justia Law

Several young Utah residents filed a lawsuit challenging statutory provisions and government actions related to fossil fuel development. They claimed that these provisions and actions were designed to maximize fossil fuel development in Utah, which they argued endangered their health and shortened their lifespans by exacerbating climate change. They sought a declaration from the district court that these provisions and actions violated their rights under the Utah Constitution.The government defendants moved to dismiss the case, arguing that the requested relief would not redress the alleged injuries. The Third District Court, Salt Lake County, agreed and dismissed the claims with prejudice, concluding that the plaintiffs lacked standing because their claims were not redressable.The Utah Supreme Court reviewed the case and affirmed the dismissal on the ground that the district court lacked subject-matter jurisdiction. The court found that the challenge to the energy policy provision was moot because the legislature had significantly amended the statute since the complaint was filed. The plaintiffs lacked standing to challenge the remaining statutory provisions because success on those challenges would not provide relief likely to redress their injuries. The court noted that the challenged provisions did not limit the government defendants' discretion in making decisions about fossil fuel development, and thus, striking these provisions would not necessarily lead to less fossil fuel development.The court also held that the challenges to the government defendants' conduct were not justiciable because they were not supported by a concrete set of facts. The plaintiffs had identified general categories of conduct without tying their claims to any specific government actions. The court instructed the district court to modify its ruling to reflect that the dismissal was without prejudice, allowing the plaintiffs the opportunity to refile their claims if they could address the jurisdictional deficiencies. View "Roussel v. State" on Justia Law

In 2016, Monte Cooke was involved in a traffic accident that resulted in one death and serious injury to another person. Cooke was charged with two second-degree felony counts for negligently driving with a measurable amount of a controlled substance in his body, causing death or serious bodily injury. Before his trial, the Utah Legislature repealed and replaced the statute under which Cooke was charged.Cooke filed a motion to dismiss the charges, arguing that he could not be prosecuted under a repealed statute. The Fourth District Court in Provo denied his motion, ruling that Utah’s general saving statute, Utah Code section 68-3-5, protects criminal prosecutions initiated before a statute’s repeal. The Utah Court of Appeals granted Cooke’s petition to appeal the interlocutory order and certified the matter to the Utah Supreme Court.The Utah Supreme Court held that Utah’s general saving statute allows a prosecution to proceed unabated when the statutory basis for the charge is repealed before trial. The court concluded that the plain language of the saving statute indicates that a statute’s repeal does not affect actions already commenced under that statute, including criminal actions. The court also determined that its decisions in Belt v. Turner and its progeny, which require the application of ameliorative sentencing amendments before sentencing, do not preclude this result. Therefore, the court affirmed the district court’s decision to proceed with Cooke’s trial under the repealed statute and remanded the case for further proceedings. View "State v. Cooke" on Justia Law