Justia Utah Supreme Court Opinion Summaries

The case concerns a criminal defendant charged with murder after an altercation in which the victim, following an argument at his own apartment, was stabbed twice in the back and later died. The defendant claimed self-defense, asserting that he acted to protect himself during a struggle after the victim re-entered the apartment and ended up on top of him. The defendant moved for a pretrial justification hearing under a Utah statute that allows the district court to determine, before trial, whether a defendant’s use of force was justified.The Third District Court held an evidentiary hearing on the defendant’s motion. At that hearing, the defendant provided both a written proffer of facts and attached exhibits, including a preliminary hearing transcript, but did not testify. The district court determined that a mere proffer of facts was insufficient and that the statutory burden required the defendant to present evidence supporting each element of the justification claim. After considering both the proffer and the exhibits, the court found that the defendant’s evidence did not show he subjectively believed the force he used was necessary to defend himself, and thus the court denied the motion to dismiss.On interlocutory appeal, the Supreme Court of the State of Utah addressed the procedural requirements of the pretrial justification statute. The court held that a defendant seeking a pretrial determination of justification must present evidence—rather than mere factual proffers—that, if believed, would be legally sufficient to satisfy each element of the justification defense. The court clarified that this is a burden of production, not a burden of proof. Applying this standard, the court concluded that the defendant failed to produce evidence supporting each element of self-defense and affirmed the district court’s denial of the motion to dismiss. View "State v. Jennings" on Justia Law

A man was charged with solicitation, conspiracy, and attempted murder after allegedly directing three women, with whom he had a polygamous relationship, to kill a fourteen-year-old girl, C.G., and her parents. The motive for the murder plot was to prevent C.G. from testifying in a pending rape case against him. The alleged plan involved the women breaking into the family’s home, but it was foiled when they were discovered, leading to their arrest. The prosecution sought to introduce evidence at trial regarding the rape case involving C.G., the defendant’s prior conviction for raping one of the co-conspirators, and the nature of his relationship with all three women, including his manipulative and coercive behavior.The Third District Court for West Jordan considered the defendant’s motion in limine to exclude this evidence. The court ruled that evidence about the rape case involving C.G. was intrinsic to the current charges, so not subject to Utah Rule of Evidence 404(b), but excluded most details about that case as irrelevant or unduly prejudicial under rules 401, 402, and 403. The court also excluded evidence of the prior rape conviction, finding it irrelevant and inadmissible under 404(b) and 403, and further excluded detailed evidence of manipulation and control over the women as unfairly prejudicial.The Supreme Court of the State of Utah granted the State’s petition for interlocutory review. The court affirmed the exclusion of the prior rape conviction under rule 403, finding its prejudicial effect outweighed its probative value. However, it held that the district court exceeded its discretion in excluding evidence about the rape case involving C.G. and the defendant’s manipulation of the women. The court adopted the rule that acts intrinsic to the charged crime are not “other acts” under 404(b), and found the probative value of this evidence was not substantially outweighed by unfair prejudice. The Supreme Court reversed the exclusions (except for the conviction) and remanded for further proceedings. View "State v. Blackwing" on Justia Law

A woman arrived at a hospital emergency room in the early morning, reporting that she had just been raped nearby. While waiting to be treated, she spoke with a police officer who asked her basic questions about the location, identity, and description of the perpetrator. The woman, visibly distressed and still processing the traumatic event, spontaneously provided additional details about the assault. Later, a Sexual Assault Nurse Examiner (SANE) conducted a medical exam, gathering information to both treat her and document injuries, and recorded the woman's statements about the assault in a standard report. The woman later died from unrelated causes.After the woman’s death, the State charged Arthur Wayne Najera with aggravated kidnapping and aggravated assault. Since the woman could not testify at trial, the State sought to admit her statements to both the officer and the nurse. Najera objected, arguing that admitting these statements would violate his Sixth Amendment Confrontation Clause rights and the rule against hearsay. The Third District Court, Salt Lake County, held several hearings and ultimately admitted both sets of statements, finding them nontestimonial and falling under the excited utterance and medical treatment exceptions to hearsay. Najera then petitioned for an interlocutory appeal.The Supreme Court of the State of Utah reviewed the interlocutory order. It held that the woman’s statements to the officer were nontestimonial because the primary purpose of the interaction was to assess the situation for immediate safety, not to collect evidence for prosecution. Those statements were also admissible as excited utterances. The court further held that the statements to the nurse were primarily for medical treatment under the circumstances and thus were also nontestimonial; they were admissible under the hearsay exception for medical diagnosis or treatment. The court affirmed the lower court’s rulings admitting both sets of statements. View "State v. Najera" on Justia Law

A property management company leased a single-family home to a tenant under an agreement that limited pets to “outside cat & chickens,” as handwritten in the lease. Despite this, the tenant kept two large dogs—a pit bull and a German shepherd—at the property. Neighbors described these dogs as aggressive, vicious, and frequently unrestrained, with some reporting prior biting incidents and expressing fear for their children’s safety. The landlord regularly visited the property but claimed to be unaware of the dogs' presence or their behavior. One day, while retrieving a baseball from the yard, a young boy was bitten by the pit bull.The boy’s father, acting as his guardian, sued the landlord in the Second District Court, Weber County, alleging negligence for allowing a dangerous condition—the pit bull—on the premises. Following discovery, the district court granted summary judgment to the landlord, holding that, as a matter of law, the landlord did not owe a duty to protect third parties from injuries caused by the tenant’s dog. The court also denied the plaintiff’s postjudgment motion challenging this ruling.On appeal, the Supreme Court of the State of Utah considered whether Utah law recognizes circumstances in which a landlord may be held liable in negligence for injuries inflicted by a tenant’s dog. The court examined several premises liability theories, including those treating the dog as a dangerous condition or activity on the land, and reviewed relevant provisions from the Restatement (Second) of Torts. Ultimately, the court found no basis under Utah law, or the proposed extensions, to impose a duty on the landlord in this context. The Supreme Court of Utah affirmed the district court’s grant of summary judgment, holding that the landlord did not owe a duty to protect third parties from injuries caused by a tenant’s dog under the facts presented. View "Tesch v. Bonneville" on Justia Law

A group of individuals who were instrumental in the campaign to incorporate the City of Erda sought to prevent approximately 8,000 acres from being annexed out of Erda and into Grantsville City. The controversy arose after an entity, Six Mile Ranch, initiated and amended an annexation petition to move land from Erda’s boundaries into Grantsville, during and after Erda’s incorporation process. The Grantsville City Recorder determined that the annexation petition met statutory requirements and certified it, which was followed by Grantsville approving the annexation by ordinance and entering a development agreement for the property. The sponsors challenged the annexation, alleging it violated both statutory requirements and constitutional provisions, and sought to invalidate the annexation ordinance and prevent the Lieutenant Governor from certifying it.In the Third District Court, Tooele County, the sponsors filed a petition for extraordinary relief under rule 65B of the Utah Rules of Civil Procedure. The district court dismissed the petition, concluding that the sponsors lacked statutory, traditional, and alternative standing to challenge the annexation, and denied related motions.On direct appeal, the Supreme Court of the State of Utah affirmed the dismissal but on alternative grounds. The court held that the sponsors, lacking statutory standing, had no other remedy for their statutory claims but failed to demonstrate that rule 65B(d)(2)(B) or the judiciary’s constitutional writ authority permitted relief where a public official had performed their statutory duty, albeit allegedly incorrectly. Regarding the constitutional claims, the court found that a plain, speedy, and adequate remedy was available through declaratory judgment actions, as clarified by recent appellate decisions. Therefore, the sponsors could not obtain extraordinary relief under rule 65B for either set of claims, and the dismissal was affirmed. View "Erda Community Association v. Baugh" on Justia Law

Police searched Franklin James’s apartment and found illegal drugs, drug paraphernalia, and firearms. The State charged him with eleven counts related to these items. James entered a plea agreement, pleading guilty to three counts in exchange for the dismissal of the remaining charges. Both parties agreed to recommend probation so James could receive drug treatment, and James wrote letters to the court expressing remorse. At sentencing, the district court rejected the probation recommendation, citing James’s criminal history and stating that treatment would be available in prison. The court sentenced James to prison and did not invite him to speak before sentencing, nor did James request to do so.James appealed to the Utah Court of Appeals, arguing that the district court violated his constitutional and statutory right to allocution by not allowing him to address the court before sentencing. He also claimed the court abused its discretion by disregarding the unanimous recommendation for probation. The court of appeals found that the failure to invite allocution was plain error and, following the Tenth Circuit’s approach in United States v. Bustamante-Conchas, held that James demonstrated prejudice simply by showing the denial of his right to allocute. The court vacated his sentence and did not reach the abuse-of-discretion claim.The Supreme Court of the State of Utah reviewed the case and reversed the court of appeals. It declined to adopt the Tenth Circuit’s rule that allocution error alone demonstrates prejudice in Utah’s sentencing regime, which differs from the federal system. The court held that, in Utah, a defendant must show case-specific prejudice from denial of allocution, and James failed to do so. The case was remanded for the court of appeals to consider James’s remaining claim regarding abuse of discretion in sentencing. View "State v. James" on Justia Law

A man was charged with murder after fatally shooting another individual in a restaurant. The defendant admitted to the shooting but claimed he acted in self-defense, believing the victim was reaching for a weapon, though the victim was unarmed. The incident followed a series of escalating personal disputes involving the defendant, his friend, and the victim. On the night of the shooting, the defendant and his companions sought out the victim at a restaurant, where a confrontation ensued, culminating in the shooting.The case was tried in the Third District Court, Salt Lake County. At trial, the defendant requested a jury instruction clarifying that actual danger is not required for self-defense—only the appearance of danger is necessary. The court declined to give this specific instruction, reasoning that the concept was already covered by the standard self-defense instructions. The defendant’s counsel was permitted to argue this point in closing. The jury convicted the defendant of murder and felony discharge of a firearm. The defendant appealed, arguing that the trial court erred in refusing his proposed instruction and that his counsel was ineffective for not objecting to witnesses referring to the decedent as “victim” and to the admission of an emotional 911 call.The Supreme Court of the State of Utah reviewed the case. It held that the district court did not abuse its discretion in refusing the defendant’s proposed jury instruction, as the instructions given adequately covered the law of self-defense. The court also found that the defendant did not receive ineffective assistance of counsel, as the use of the term “victim” by witnesses was not unreasonable in context, and the admission of the 911 call did not prejudice the outcome. The Supreme Court affirmed the convictions. View "State v. Hunt" on Justia Law

A long-term employee of a county government began experiencing workplace difficulties after a new supervisor was assigned. The employee alleged that the supervisor engaged in repeated, unwelcome comments about her appearance and closely monitored her, behavior corroborated by coworkers. After reporting the supervisor’s conduct to union representatives, who then informed higher management, the employee was subjected to increased scrutiny, including a performance improvement plan, a written warning, and public criticism of her work. The employee filed internal and external complaints alleging sexual harassment and retaliation. Following these events, her health deteriorated, leading her to take medical leave and ultimately retire early.The Utah Labor Commission’s Antidiscrimination and Labor Division initially found no reasonable cause for her claims. On appeal, an administrative law judge (ALJ) held an evidentiary hearing but was replaced by another ALJ, who dismissed her claims. The Labor Commission Appeals Board reviewed the case, reinstated her retaliation claim using the McDonnell Douglas burden-shifting framework, and remanded for a damages determination. The Board and ALJ denied her request for attorney fees, citing a Utah Supreme Court decision, Injured Workers Ass’n of Utah v. State, as precluding such awards. Both parties appealed aspects of the Board’s decision to the Utah Court of Appeals, which adopted the U.S. Supreme Court’s Burlington Northern standard for “adverse action” in retaliation claims, upheld the retaliation finding, and ruled that attorney fees could be awarded but not assessed for reasonableness.The Supreme Court of the State of Utah reviewed the case. It held that the Burlington Northern standard—defining adverse action as conduct likely to dissuade a reasonable worker from making or supporting a discrimination charge—applies to retaliation claims under the Utah Antidiscrimination Act. However, the court found the Board had not applied this standard or made sufficient factual findings, so it remanded the case for further proceedings. The court also clarified that the McDonnell Douglas framework is a procedural device, not a set of claim elements, and that the Labor Commission may award and assess the reasonableness of attorney fees. The court affirmed in part, reversed in part, and remanded. View "Christensen v. Labor Commission" on Justia Law

In 1988, a defendant was convicted of first-degree murder and sentenced to death. Decades later, after exhausting his appeals, he was diagnosed with vascular dementia, a progressive neurocognitive disorder that impairs memory and cognitive function. When the State sought an execution warrant in early 2024, the defendant filed a petition asserting that his dementia rendered him incompetent to be executed under the Eighth Amendment, which prohibits executing individuals who cannot rationally understand the reason for their execution.The Third District Court, Salt Lake County, held an evidentiary hearing with multiple expert witnesses. Although it was uncontested that the defendant suffered from vascular dementia and had experienced cognitive decline, the court found him competent to be executed, concluding he retained a rational understanding of the reason for his death sentence. The defendant appealed and requested a stay of execution, which the district court denied. Subsequently, he filed a petition for reevaluation, supported by new expert reports and observations indicating further rapid decline and an inability to understand the connection between his crime and punishment. The district court denied this petition, finding no substantial change in circumstances and no significant question about competency.The Supreme Court of the State of Utah reviewed both the appeal of the first competency order and the denial of the reevaluation petition. The court held that a successive competency petition must make a prima facie showing of a substantial change of circumstances and raise a significant question about competency. The district court erred by weighing rebuttal evidence at this threshold stage and by concluding the defendant failed to meet the statutory requirements. The Supreme Court reversed the order denying reevaluation and remanded for further proceedings. The appeal of the first competency order and one petition for extraordinary relief were deemed moot. View "State v. Menzies" on Justia Law

A man was charged with multiple offenses, including aggravated sexual assault and aggravated assault, after an incident in which a woman alleged he raped her at gunpoint in his car. At trial, the woman and the defendant gave conflicting accounts: she described a violent, non-consensual encounter involving threats and physical force, while he claimed the encounter was consensual. Physical evidence, including injuries documented by a sexual assault nurse examiner (SANE), and corroborating witness testimony supported the woman’s account. The jury convicted the defendant of aggravated sexual assault and aggravated assault, and he was sentenced to concurrent prison terms.Following his conviction, the defendant pursued posttrial motions in the Third District Court, including claims of a Brady violation and ineffective assistance of trial counsel. The trial court denied these motions after an evidentiary hearing. On direct appeal, the Utah Court of Appeals affirmed the convictions, and the Supreme Court of the State of Utah later affirmed on certiorari, rejecting arguments related to jury instructions and the alleged Brady violation.The defendant then filed a petition for postconviction relief, later amended to include claims of due process violations, the right to present a complete defense, and ineffective assistance of both trial and appellate counsel. The State moved for summary judgment, and the defendant filed a combined opposition and cross-motion for summary judgment. The postconviction court granted the State’s motion, struck the defendant’s cross-motion as procedurally improper, and found the defendant’s claims either procedurally barred or lacking in prejudice.On appeal, the Supreme Court of the State of Utah affirmed the postconviction court’s grant of summary judgment for the State and its decision to strike the defendant’s cross-motion. The Court clarified that while postconviction petitioners may not combine a response and a motion in a single document, nothing in the Post-Conviction Remedies Act or Utah Rules of Civil Procedure prohibits petitioners from filing their own motions for summary judgment. View "Newton v. State" on Justia Law