Justia Utah Supreme Court Opinion Summaries

After the first day of a criminal trial for aggravated assault, the presiding judge disclosed that he was related by marriage to one of the State’s witnesses. The defendant then moved to disqualify the judge, citing concerns about public perception of impartiality. The motion was referred, as required, to the district’s presiding judge, who granted it, vacated the trial, and transferred the case to another judge without giving the parties an opportunity to object. The jury was excused, and the proceedings were reassigned.Subsequently, the State amended the charges and sought an expedited trial before the new judge. Before the new trial began, the defendant moved to dismiss, arguing that retrial was barred by Utah’s double jeopardy protections since the jury had been discharged without either his consent or a showing of legal necessity. The new trial judge denied the motion, finding that the circumstances made the mistrial legally necessary because there were no reasonable alternatives, primarily due to logistical difficulties in promptly reassigning the case to another judge. The defendant appealed.The Utah Court of Appeals reversed, holding that the legal necessity exception to double jeopardy could not apply because the parties had not been afforded an opportunity to object before the mistrial was declared. The court of appeals concluded that this omission alone barred retrial.On certiorari, the Supreme Court of the State of Utah held that failing to afford the parties an opportunity to object before declaring a mistrial does not, by itself, preclude application of the legal necessity exception to Utah’s double jeopardy protection. The court explained that if the record shows there were no reasonable alternatives to a mistrial under the circumstances, retrial is not barred, even without an opportunity to object. The court reversed the decision of the court of appeals and remanded for further proceedings to determine whether reasonable alternatives existed. View "State v. Mitton" on Justia Law

After an evening of heavy drinking and marijuana use, the appellant shot and killed Randy Lewis, who was unarmed, during an escalating argument at a friend’s home. The appellant claimed that he acted in self-defense, stating that the victim had threatened him and may have reached for a knife, although no physical evidence supported the presence of a weapon. The appellant fled the scene, later sent a deceptive message to the friend, and gave inconsistent accounts of the incident to various people.The case was first tried in the Second District Court, Davis County. The State charged the appellant with murder and felony firearm possession for having a gun while under the influence of marijuana. At trial, the appellant’s counsel argued that the self-defense statute should not bar his claim unless he was committing a “forcible felony,” or that the statute’s application would violate the Utah Constitution. The district court rejected these arguments, instructing the jury that self-defense was unavailable if the defendant was committing any felony. The jury convicted the appellant of murder and felony firearm possession but acquitted him of aggravated assault. On direct appeal, the appellant’s counsel challenged the jury instruction but failed to argue prejudice, and the Utah Court of Appeals affirmed because prejudice was not shown.The appellant then sought postconviction relief, arguing ineffective assistance of trial and appellate counsel. The postconviction court granted summary judgment for the State, finding no prejudice due to overwhelming evidence of guilt. On appeal, the Supreme Court of the State of Utah affirmed. The court held that, even if the jury instructions had been different, there was not a reasonable likelihood of a more favorable result for the appellant, given the evidence against him. Thus, the appellant failed to demonstrate prejudice, and his ineffective assistance of counsel claims did not succeed. View "Fenstermaker v. State" on Justia Law

The defendant pled guilty to aggravated kidnapping based on unlawful detention and was sentenced in the Third District Court, Salt Lake County, to fifteen years to life in prison. After his sentencing, but while his direct appeal was pending, the Utah legislature amended the relevant statute, reducing the penalty for his offense from a first-degree to a third-degree felony. The defendant then sought resentencing under the new, lesser penalty, arguing that the common law amelioration doctrine entitled him to the benefit of the statutory reduction because his case was not yet final.Previously, the Utah Court of Appeals had remanded the case for resentencing after determining that the State breached the plea agreement; on remand, the district court imposed the same sentence. The defendant’s subsequent appeal resulted in affirmance of his sentence. Only after the appellate court’s decision, and after the statutory reduction had been enacted, did he move for resentencing under Utah Rule of Criminal Procedure 22(e). The district court denied his motion, reasoning that Utah law bases sentencing on the statute in effect at the time of sentencing, not on subsequent amendments, even if the case is still on appeal.The Supreme Court of the State of Utah reviewed the case. It held that under Utah’s general savings statute, a criminal penalty is “incurred” at the time of sentencing. Therefore, any statutory reduction enacted after sentencing does not apply, even if the defendant’s direct appeal is still pending. The court concluded that the amelioration doctrine, which would allow application of the lesser penalty before a case is final, is inconsistent with the statute and Utah precedent. As a result, the court affirmed the district court’s denial of resentencing and upheld the original sentence. View "State v. Featherston" on Justia Law

After two children lost their parents in a helicopter accident, their maternal and paternal grandmothers were appointed as coguardians. Over time, the relationship between the grandmothers deteriorated, leading the paternal grandparents to file a petition to adopt the children. The maternal grandmother intervened in that proceeding, then, together with her husband, filed a separate adoption petition. The paternal grandmother received proper legal notice of this competing adoption proceeding, which warned her that she needed to intervene within thirty days if she wished to contest the adoption or risk losing all rights regarding the children. Despite this notice, she did not file a motion to intervene.The Eighth District Court consolidated the cases briefly, then separated them to proceed independently. After deconsolidation, the maternal grandparents served notice again, but the paternal grandmother still did not intervene. The maternal grandmother moved for partial summary judgment, arguing that the paternal grandmother should be barred from pursuing her adoption petition due to her failure to intervene. The district court agreed and barred both paternal grandparents from proceeding. The paternal grandmother petitioned for interlocutory review, and the Utah Court of Appeals reversed, holding that barring the paternal grandmother but not the paternal grandfather from maintaining their petition produced an absurd result, given the statutory scheme.The Supreme Court of the State of Utah reviewed the case and reversed the appellate court’s decision. It held that the plain language of the Utah Adoption Act’s intervention provision requires a person who receives notice of an adoption proceeding and wishes to contest it to intervene within thirty days, or forfeit all rights to the adoptee, including the ability to bring or maintain any related action. The court found that the appellate court’s application of the absurdity doctrine was based on a hypothetical scenario, not the actual district court ruling, and concluded that the statutory result was not so overwhelmingly absurd as to justify departure from the statute’s plain language. The Supreme Court affirmed the district court’s summary judgment. View "In re Adoption of R.P." on Justia Law

A fatal collision occurred when a Volkswagen Jetta, driven by Raul Lopez with Emilio Martinez-Arroyo as a passenger, rear-ended a utility trailer owned by Ron J. Peterson Construction, Inc. (RJP) on a Utah highway. The trailer, which was transporting construction equipment and did not have underride protection, was traveling significantly below the speed limit with its emergency flashers on. Both occupants of the Jetta died instantly after their car slid under the trailer. Yesneiri Maldonado-Velasquez, the decedent’s wife, sued RJP alleging negligence both in operating the vehicle and in using a trailer that lacked safety features that could have mitigated the injuries.In the Third District Court, Summit County, RJP moved for summary judgment, arguing that it had no duty to upgrade the trailer beyond federal safety standards and that the crash was solely caused by Lopez. The district court found a general statutory duty to operate safe equipment but determined that there was no specific duty to alter the trailer, based on federal preemption and application of factors from B.R. ex rel. Jeffs v. West. As a result, the court excluded much of the plaintiff's expert testimony on enhanced injury and trailer design, allowing only claims related to negligent operation. The jury ultimately found RJP not at fault.On direct appeal, the Supreme Court of the State of Utah held that the district court erred by applying the Jeffs factors to narrow an already established broad statutory duty to operate safe vehicles. The Supreme Court clarified that federal regulations set a minimum standard, not a ceiling, and that state law may impose greater obligations unless direct conflict preemption applies. The court also held that the exclusion of expert testimony premised on the erroneous duty ruling was an abuse of discretion. The Supreme Court reversed and remanded for further proceedings consistent with its opinion. View "Maldonado-Velasquez v. Ron J Peterson Construction" on Justia Law

A real estate developer and his company sought to develop a large project in Fillmore, Utah, but encountered significant obstacles, including difficulties in securing land, water, and city approvals. The developer promoted the project publicly and requested city support, which drew media attention. A local newspaper and its reporter investigated the developer’s history and published a series of articles portraying him in a negative light, referencing past lawsuits, bankruptcies, and failed ventures. After the city rejected the project, the developer sued the newspaper and reporter for defamation, alleging that the articles contained false statements that caused lenders to withdraw support, resulting in substantial financial losses.The case was heard in Utah’s Fourth District Court. The defendants responded to the complaints and filed a special motion for expedited relief under Utah’s Uniform Public Expression Protection Act (UPEPA), arguing that the challenged statements were true, opinion, or otherwise protected. The district court granted the special motion, dismissing the defamation claims after a detailed review of each statement and finding them either true, vague, opinion, or privileged. The court admonished the plaintiff for certain litigation tactics and subsequently, upon the defendants’ request, awarded them nearly $400,000 in attorney fees and costs, accepting their submission without a task-by-task analysis of whether each fee was “related to” the special motion.On direct appeal, the Supreme Court of the State of Utah reviewed the fee award. The court held that a prevailing defendant in a UPEPA special motion must demonstrate that each fee was reasonably necessary to prosecute the special motion, not simply related to the case as a whole. Fees not meeting this standard are not awardable. The Supreme Court reversed the district court’s fee award, excluded certain fees, and remanded for further proceedings to determine relatedness and reasonableness consistent with its opinion. View "Aston v. Chronicle-Progress" on Justia Law

After an argument at an apartment, Deon Andre Jennings was charged with the murder of Willie Houston. During the confrontation, Houston asked Jennings to leave several times, but Jennings refused. When Houston stepped outside, Jennings attempted to lock him out, but Houston forced his way back in, ending up on top of Jennings. While on the floor, Jennings struck Houston in the back multiple times with an object. Houston left the apartment, sought help, and later died from deep stab wounds. Jennings claimed self-defense, asserting he struck Houston only to get him off, not to kill him, and that he did not know what object he used.The Third District Court, Salt Lake County, conducted a pretrial justification hearing under Utah Code section 76-2-309, which allows for an evidentiary hearing on self-defense before trial. Jennings argued that a written proffer of facts was sufficient to make a prima facie claim of justification, while the State contended evidence was necessary. The district court found that a proffer alone was not enough; it considered both Jennings’ proffer and his attached exhibits. The court determined that Jennings’ evidence did not support a claim that he reasonably believed force was necessary to defend himself, and found that Houston had not threatened or physically assaulted Jennings.The Supreme Court of the State of Utah affirmed the district court’s ruling. It held that, to make a prima facie claim of justification under the statute, a defendant must present evidence at the hearing that, if believed, would be legally sufficient to satisfy each element of a justification defense. This is a burden of production, not of proof. Because Jennings failed to present evidence indicating he subjectively believed the force he used was necessary for self-defense, the denial of his motion to dismiss was affirmed. View "State v. Jennings" on Justia Law

Two former seasonal employees of a ski resort were injured in a snowmobile accident after being laid off from their jobs. The accident occurred when, two days after their termination, they returned to the resort to drop off uniforms and accepted a ride from a current employee on a company snowmobile to attend a gathering organized by other former employees. The snowmobile crashed, causing serious injuries. Prior to their employment, both injured parties had signed a release agreement that waived the resort’s liability for injuries sustained from activities on resort property, including those caused by the resort’s negligence. The agreement specified that a free ski pass was consideration for the waiver.Both individuals brought lawsuits against the resort alleging vicarious liability for the employee’s negligence and direct liability for its own negligence. The Third District Court, Summit County, granted summary judgment in favor of the resort on the vicarious liability claims, finding no evidence the employee was acting within the scope of employment during the snowmobile ride. However, the district court denied summary judgment on the direct liability claims, relying on Pugmire v. Oregon Short Line Railroad Co., a 1907 Utah Supreme Court decision holding that employer-employee agreements waiving liability for employer negligence are void as contrary to public policy.On interlocutory appeal, the Supreme Court of the State of Utah affirmed the dismissal of the vicarious liability claims, concluding that there was no factual basis for a jury to find the employee acted within the course and scope of his employment. The court reversed the district court’s ruling on direct liability, holding that Pugmire applies only to releases for work-related injuries and does not bar enforcement of the waiver in this case, where the injuries occurred outside the employment context. The case was remanded for consideration of any other arguments regarding the release agreement. View "Deer Valley v. Olson" on Justia Law

Michael Johnson was charged with murder in connection with a death where the cause was disputed and involved conflicting evidence regarding physical injuries and substance use. At trial, Johnson’s counsel requested that the jury receive an instruction on the lesser-included offense of homicide by assault. However, the instruction given, which was drafted and approved by Johnson’s counsel, mischaracterized the required mens rea for homicide by assault. The jury convicted Johnson of intentional murder.On appeal, Johnson did not argue that his counsel was ineffective for proposing the erroneous instruction, nor did he claim the trial court committed plain error. Despite this, the Utah Court of Appeals raised the instructional error sua sponte and, applying the exceptional circumstances exception, found the error prejudicial and reversed the conviction. The Supreme Court of the State of Utah granted certiorari and reversed the Court of Appeals, holding that it was improper to address the instructional error under the exceptional circumstances exception since it had not been preserved or raised by the parties. The case was remanded, and the Court of Appeals summarily affirmed Johnson’s conviction.Johnson then sought postconviction relief, arguing his trial and appellate counsel were ineffective for failing to challenge the jury instruction. The Third District Court found deficient performance but concluded Johnson suffered no prejudice because the instruction’s first element required the jury to rule out murder before considering the lesser offense. Since the jury convicted on murder, the court found no reasonable probability of a different outcome.The Supreme Court of the State of Utah affirmed, holding that its prior decision vacated the Court of Appeals’ prejudice analysis, leaving the district court free to make its own ruling. It further held that Johnson could not establish prejudice, as the unchallenged first part of the instruction precluded conviction on the lesser offense once the jury found murder. View "Johnson v. State" on Justia Law

A defendant was charged with murder following an altercation at an apartment, where the victim died from stab wounds to his back. The defendant claimed he acted in self-defense, stating that the victim had ordered him to leave, attempted to re-enter forcefully, and ended up on top of him during a struggle. The defendant then struck the victim multiple times with an unknown object. There was no evidence or claim that the victim was armed or had threatened to use a weapon, and the victim subsequently sought help from a neighbor before succumbing to his injuries.The Third District Court in Salt Lake County held a pretrial justification hearing pursuant to Utah Code section 76-2-309. The defendant argued that he could make a prima facie claim of justification merely by proffering facts, which should be accepted as true. However, the district court interpreted the statute to require more than a proffer and considered both the defendant’s proffer and attached exhibits. The court found that the evidence did not support the defendant’s assertion of self-defense, as there was no indication he reasonably believed force was necessary to defend against imminent unlawful force or a forcible felony. Thus, the court denied the motion to dismiss.The Supreme Court of the State of Utah reviewed the interlocutory appeal. It held that to make a prima facie claim of justification under the statute, a defendant must present evidence at the hearing that, if believed by the factfinder, would be legally sufficient to satisfy each element of the justification claim. This is a burden of production, not of proof. The court concluded that the defendant had not presented 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