Justia Utah Supreme Court Opinion Summaries

This case involves two children who were removed from their parents’ custody in 2015 due to neglect and abuse but were returned after their parents participated in services. In 2019, the State again removed the children following similar findings of neglect, unsanitary conditions, and developmental delays. Mother left the country for a year, leaving the children with father, who also failed to provide appropriate care. The children were placed with foster parents in Tennessee who wished to adopt them. After reunification efforts failed, the State filed a petition to terminate both parents’ rights. Mother only began accessing services after the petition was filed.The Fourth District Juvenile Court held a first trial in 2021 and terminated Mother’s parental rights, but the court’s order failed to adequately explain alternatives to termination. Mother’s initial appeal to the Utah Court of Appeals was dismissed as untimely. She then sought relief in juvenile court, which re-entered the order, allowing her to appeal again. The parties later stipulated that the juvenile court’s best interest findings were insufficient, and the Court of Appeals reversed and remanded for further analysis. A second trial was held, and the juvenile court issued a new order in December 2023, again terminating Mother’s parental rights, finding neglect, parental unfitness, and that termination was strictly necessary for the children’s welfare.On appeal, the Supreme Court of the State of Utah addressed jurisdictional questions arising from the untimely appeal and prior proceedings. The court held that it had appellate jurisdiction over Mother’s challenge to the juvenile court’s post-remand December 17, 2023 order, but lacked jurisdiction over alleged errors predating the first appeal. The court affirmed the juvenile court’s determination that termination was strictly necessary to promote the children’s best interest and rejected Mother’s claims that the decision lacked evidentiary support. View "In re J.A.C." on Justia Law

A man was cited and charged in the Salt Lake City Justice Court after allegedly causing a car accident while driving under the influence of alcohol. The charges included a class B misdemeanor for DUI, as well as other related offenses. Several months after the charges were filed, the defendant attempted to plead guilty, but the City refused to consent, invoking a state law requiring prosecutorial approval for guilty pleas in DUI cases. The justice court declined to accept his plea without the City’s consent.The defendant then moved the justice court to declare the prosecutorial consent law unconstitutional, arguing it violated Utah’s separation of powers doctrine and his due process rights. While this motion was pending, the Salt Lake County District Attorney filed enhanced, felony-level charges against him in the district court. The City moved to dismiss the justice court case without prejudice, and the justice court denied the defendant’s constitutional challenge, finding no violation of the separation of powers and concluding the due process argument was inadequately briefed. The case in the justice court was dismissed without prejudice.The Supreme Court of the State of Utah reviewed the defendant’s petition for extraordinary relief. The court found that the defendant had properly invoked its authority for relief under Utah Rule of Appellate Procedure 19 regarding the separation of powers claim, since no direct appeal was available. However, the court declined to reach the merits or grant relief, holding that the defendant had not shown he was likely to benefit from a favorable ruling because felony charges were already pending in district court and it was speculative that the justice court would accept his guilty plea. The court also rejected the due process challenge, finding the defendant had not addressed the justice court’s basis for rejection. The petition for extraordinary relief was denied. View "Adams v. Hon. Robison" on Justia Law

The appellant was convicted by a jury of multiple child sexual abuse offenses. After his convictions were affirmed on direct appeal by the Utah Court of Appeals, and after the Utah Supreme Court denied certiorari, he filed a petition for post-conviction relief in the Fourth District Court. His initial petition raised claims that had already been addressed on direct appeal, leading the district court to dismiss it as procedurally barred. Subsequently, new counsel moved to set aside the dismissal, arguing he had been deprived of notice and a hearing. The district court granted the motion and reinstated the petition. The appellant then sought and received leave to amend his petition, but the amended version included new claims and was filed after the one-year statute of limitations imposed by the Post-Conviction Remedies Act (PCRA).The State moved to dismiss the amended petition as untimely, contending that the new claims did not relate back to the original petition under Utah Rule of Civil Procedure 15(c). The district court agreed, finding that the new claims were entirely different from the original claims and did not satisfy the relation-back requirements. The court rejected the appellant’s argument that Utah Rule of Civil Procedure 65C(h)(3) independently allowed the amendment regardless of timeliness, and also dismissed his assertions that the application of Rule 15(c) was discretionary or that the PCRA’s time bar was unconstitutional. The appellant timely appealed; the case was briefly transferred to the Utah Court of Appeals before being recalled by the Supreme Court of Utah.The Supreme Court of Utah affirmed the district court’s dismissal. The court held that Rule 15(c) applies to post-conviction petitions and that Rule 65C(h)(3) does not override the relation-back requirement. It clarified that neither its precedent nor the Utah Constitution invalidates the PCRA’s one-year time bar or requires an “interests of justice” exception. Accordingly, the dismissal of the amended petition as untimely was upheld. View "Nunez v. State" on Justia Law

A man was accused of sexually abusing and raping his niece when she was a child. The alleged abuse occurred over several years, beginning when the niece was approximately nine or ten years old and continuing until she was about twelve. The niece did not disclose the abuse at the time, but years later, after becoming an adult, she reported the incidents to law enforcement. The prosecution relied heavily on her testimony, as well as testimony from an expert witness who described general patterns in child sexual abuse disclosures, and evidence regarding text messages sent by the accused to the niece.At trial in the Third District Court, a jury convicted the defendant on four counts of aggravated sexual abuse of a child and one count of rape of a child. The defense raised several objections and arguments, including challenges to the admissibility of the expert witness testimony under Utah Rule of Evidence 702, claims of ineffective assistance of counsel for not objecting to the use of the term "victim" at trial, and assertions that the niece’s testimony was inherently improbable and therefore insufficient to support a conviction. The trial court denied a motion for directed verdict and allowed the challenged evidence and arguments over defense objections.The Supreme Court of the State of Utah reviewed the case on direct appeal. The court held that the defendant had waived much of his challenge to the expert testimony by abandoning those arguments in the trial court, and he failed to establish that his counsel was ineffective in handling the expert’s statements or the use of the word “victim.” The court also found that counsel’s decision not to object to testimony about the niece’s self-harm or to raise a challenge based on inherent improbability did not constitute deficient performance. The court affirmed the convictions, finding no reversible error or cumulative prejudice. View "State v. Castillo" on Justia Law

Two children were born to their biological parents in 2013 and 2014. The parents’ relationship was unstable and marked by frequent separations, substance abuse, and incidents of violence and neglect that placed the children in danger. Over the years, the children experienced episodes of direct harm, including exposure to controlled substances and physical endangerment. After a series of disruptive events involving both parents, the children were placed in the full-time care of their maternal grandparents in July 2020, following interventions by child protective services. Since that time, the parents have had little or no meaningful contact with the children, and the grandparents have provided a stable, nurturing environment.After the grandparents petitioned to adopt the children and terminate the parents’ rights, the Eighth District Court conducted a bench trial. The court made detailed factual findings about the parents’ ongoing substance abuse, instability, and inability to protect or care for the children. It concluded that statutory grounds for termination were met, including abandonment, neglect, unfitness, and token efforts to avoid harm. The district court further found that termination was in the children’s best interests and granted the adoption, but did not expressly determine whether termination was “strictly necessary” to promote the children’s best interests or consider alternatives short of termination.The Supreme Court of the State of Utah reviewed the case on certification from the Court of Appeals. The court held that, under Utah law, a court must find that termination of parental rights under the Adoption Act is “strictly necessary” to promote the child’s best interest, incorporating this requirement from the Termination and Restoration of Parental Rights Act. However, the Supreme Court found that the district court’s failure to make a specific strictly necessary finding was harmless error, given the unchallenged factual findings that no feasible alternative short of termination could protect the children. The decision of the district court was affirmed. View "Ross v. Kracht" on Justia Law

After a father was incarcerated for sexual abuse of a minor in 2013, his contact with his four children became sporadic, limited mostly to phone calls and occasional cards or gifts. The children, three of whom have special needs, lived with their mother, who moved back to Utah and eventually divorced the father. She later remarried, and her new husband became a father figure to the children. In 2020, the mother and stepfather sought to adopt the children, amending their petition to also request the termination of the biological father’s parental rights.The Second District Court in Weber County held a two-day hearing, considering testimony from family members and experts regarding the children’s needs and the impact of potential disruption to their stability. The district court found clear and convincing evidence for four grounds of termination: abandonment, neglect, unfitness, and token efforts. It further determined that termination was strictly necessary to promote the children’s best interest, especially given their susceptibility to instability due to special needs. The court rejected alternatives such as continuing the status quo or establishing guardianship, finding these would risk future litigation and undermine stability.The Utah Supreme Court, reviewing the case on certification from the Court of Appeals, applied a deferential standard and focused solely on whether the district court’s determination that termination was strictly necessary was against the clear weight of the evidence. The Supreme Court concluded that the district court had properly conducted a particularized analysis of the children’s needs, rejected speculative or categorical concerns, and relied on evidence regarding the likely disruption from the father’s reentry. The Supreme Court affirmed the district court’s decision, holding that the termination of parental rights under the Utah Adoption Act must be strictly necessary to promote the child’s best interest, and that this standard was met in the present case. View "In re Adoption of B.C." on Justia Law

The case concerns a dispute between an executive and a start-up company arising from employment and compensation arrangements. The executive, recruited for his expertise in the hemp industry, was offered a below-market salary due to the company’s limited resources. To compensate for the reduced salary, he was granted stock options, which he exercised through a non-recourse promissory note. After discovering that the company had misrepresented important information about its technology and operations, the executive sued under Utah securities laws for making untrue statements of material fact.Following a bench trial, the Third District Court found the company had intentionally violated Utah Code section 61-1-1 but determined that neither party had presented adequate evidence regarding the “consideration paid for the securities.” When questioned about damages, the executive stated he could not calculate the value. The district court independently identified three potential methods for calculating damages, including the so-called “Note Theory,” which valued damages by the amount of the promissory note. The district court, however, found this approach too speculative and instead awarded damages based on the difference between the executive’s actual salary and the market rate, ultimately tripling the award due to the intentional violation.On appeal, the executive argued that the district court should have used the Note Theory to calculate damages. The Utah Court of Appeals concluded that the executive had not preserved this argument for appeal because he had not presented it to the district court. The Supreme Court of the State of Utah reviewed the case and affirmed the court of appeals. The Supreme Court held that, although a district court’s sua sponte consideration of an issue can sometimes preserve it for appeal, in this instance, doing so would not serve the principles of judicial economy or fairness. Therefore, the Note Theory was unavailable to the executive on appeal. View "Abu-Ulba v. Ananda Scientific" on Justia Law

After a motor vehicle collision, the plaintiff sued both the driver, who was allegedly intoxicated, and five bars under Utah’s Alcoholic Product Liability Act, claiming the bars overserved the driver prior to the crash. The plaintiff settled with the driver and three of the bars for a combined $1 million, resulting in dismissal of all claims against those parties. Two of the bars that participated in the settlement then sought contribution from the driver under Utah Code section 32B-15-302(1)(a), arguing they were entitled to recover part of the settlement amount from him.The Third District Court granted summary judgment in favor of the driver, finding that the term “award” in the Dramshop Act’s contribution provision refers to an amount imposed by a court or authority, not to payments made in voluntary settlements. Since the bars settled the claims, the court concluded no “award” was made against them, and dismissed their crossclaims. The Utah Court of Appeals affirmed, determining that “award” in the statute does not encompass voluntary settlements and supporting its interpretation with reference to the statute’s language and context.The Supreme Court of the State of Utah granted certiorari and reviewed the statutory interpretation de novo. The Court held that the Dramshop Act’s contribution provision permits contribution claims only when a party has an award imposed against them, not when they make voluntary settlement payments. The Court rejected arguments that common law or policy required a broader reading. Accordingly, it affirmed the appellate court’s judgment, holding that parties who settle claims under the Act cannot pursue contribution against other alleged wrongdoers. View "RMB v. Celotto" on Justia Law

Police stopped a man for a traffic violation late at night. During the stop, officers smelled marijuana, searched the car, and found drugs and a gun. The man’s brother, who was in the car, told police that there might be evidence of drug possession and use at their home. The police officer then applied for two search warrants: one to search the home for evidence of drug dealing, and another to collect the man’s blood and DNA. The officer intended to request permission for nighttime searches but failed to do so due to a technical omission—he did not check the box in the electronic application system that would have prompted him to justify nighttime execution. As a result, both warrants were issued for daytime only. Despite this, officers executed both warrants during nighttime hours.The Second District Court reviewed the defendant’s motion to suppress evidence obtained from the nighttime execution of the daytime-only warrants. After an evidentiary hearing, the court found that the officer’s failure to request nighttime authorization was inadvertent, not malicious or in bad faith. The court also acknowledged that the magistrate would likely have granted nighttime authorization if it had been requested. Nevertheless, the court suppressed the evidence, concluding that the plain language of rule 40(e)(1) of the Utah Rules of Criminal Procedure required magistrate authorization for nighttime searches and that non-compliance with this requirement warranted suppression, regardless of the absence of prejudice or bad faith.The Supreme Court of the State of Utah reviewed the case on certification from the Utah Court of Appeals. It held that, under prior precedent, suppression is not required for a violation of rule 40(e)(1) unless the violation also infringes constitutional rights, is committed in bad faith, or prejudices the defendant. Because the district court found neither bad faith nor prejudice and did not determine there was a constitutional violation, the Supreme Court reversed the suppression order and remanded for further proceedings. View "State v. Jaramillo" on Justia Law

A high school student, J.M., and her sisters initiated a physical altercation with another student at school, during which J.M. allegedly shoved a teacher into a wall and punched the student. The teacher later discovered he had a fractured rib, and the student sustained visible injuries. The school resource officer referred the incident to juvenile court, listing misdemeanor assault as the offense. A juvenile probation officer screened the case, classified it as a misdemeanor, and offered J.M. a nonjudicial adjustment agreement, which she accepted and began fulfilling by completing community service.After J.M. completed her community service but before restitution had been resolved, the State disagreed with the misdemeanor classification and filed a delinquency petition alleging three felony offenses: aggravated assault, assault, and riot, all stemming from the same incident. J.M. moved to dismiss the petition, arguing that prosecutors could not file charges after substantial compliance with the nonjudicial adjustment. The Third District Juvenile Court denied her motion, reasoning that no statute or rule precluded the State from filing a petition if it viewed the case as involving new allegations or a more serious offense.On interlocutory appeal, J.M. maintained that under Utah statutes governing nonjudicial adjustments, the probation officer’s eligibility determination should control and limit prosecutorial authority. The Supreme Court of the State of Utah reviewed the case and held that Utah’s Juvenile Code does not bar a prosecutor from filing a petition when a nonjudicial adjustment has been improperly offered for a disqualifying offense. The determination of whether an offense is disqualifying, such as a felony committed by a minor over age twelve, is an objective legal question not controlled by the referral or probation officer’s assessment. Because J.M. challenged only the prosecutor’s authority, not the felony characterization, the Supreme Court affirmed the juvenile court’s denial of the motion to dismiss. View "In re J.M." on Justia Law