Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of two counts of aggravated sexual abuse, holding that the district court did not err in concluding that there was sufficient evidence to sustain Defendant's convictions.On appeal, Defendant argued that the district court erred by denying his motion for a directed verdict and a motion to arrest judgment. Specifically, Defendant argued that the State presented insufficient evidence to convict him because the victim recanted her story that Defendant had inappropriately touched her. The Supreme Court affirmed, holding that the jury was entitled to weigh the two versions of the victim's story, consider the other evidence of Defendant's guilt, and decide which version of the victim's story it found to be credible. View "State v. Stricklan" on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated robbery, holding that the trial court did not plainly err in its handling of the State's reports of a sleeping juror and that defense counsel did not provide ineffective assistance.On appeal, Defendant asserted that he was denied his Sixth Amendment right to a jury trial because at least one juror allegedly slept during the proceedings. The court of appeals concluded that Defendant failed to demonstrate that the trial court plainly erred in declining to inquire into the attentiveness of the juror and that Defendant failed to demonstrate that his trial counsel provided ineffective assistance in responding to observations that the juror may have been sleeping. The Supreme Court affirmed, holding (1) a trial court should respond to a report of an inattentive or drowsy juror in a manner that is proportional to the report before it, but the trial court in this case did not plainly err in its response; and (2) Defendant failed to show that his counsel's actions were deficient. View "State v. Marquina" on Justia Law

The Supreme Court reversed in part the judgment of the district court in favor of Plaintiffs on their claims of interference and negligence, holding that the district court erred in determining that Defendants interfered with Plaintiffs' wells and that remand was necessary on the negligence claim to consider whether it survives the dismissal of Plaintiffs' interference claims.Plaintiffs diverted their water obtained through their water rights through the use of two wells. Defendant had a junior water right and operated five wells that were deeper and stronger than Plaintiffs' wells. Plaintiffs brought this lawsuit alleging interference and negligence, claiming that Defendant interfered with their water rights because when one of Defendant's wells operated it lowered the water table and put the available water beyond the reach of Plaintiffs' pumps. The district ruled in favor of Plaintiffs. The Supreme Court (1) reversed the district court's determination of interference, holding that Plaintiff failed to prove interference; and (2) declined to reverse the negligence ruling but, in light of the reversal of the district court's interference determinations, remanded this claim for reconsideration and further fact-finding, if necessary. View "Arave v. Pineview West Water Co." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals setting aside the adoption decree in this case, holding that the district court's conclusions of law in support of the adoption decree were inadequate.Mother, a Montana resident, gave birth to a child in Montana. Mother placed the child for adoption with Respondents, two Utah residents. On a form required under the Interstate Compact on the Placement of Children (ICPC), Utah Code 62a-4a-701 to -711, Mother did not list Petitioner, the child's legal father, as the child's father. Respondents filed an adoption petition and petitioned to terminate Petitioner's parental rights. The district court terminated Petitioner's parental rights and finalized the adoption. The court of appeals set aside the adoption decree because it did not state that the requirements of the ICPC had been complied with, as required by the Adoption Act. The Supreme Court affirmed and remanded the case, holding (1) there was no jurisdictional defect under the ICPC or the Adoption Act; but (2) the district court's conclusions of law in support of the adoption decree were inadequate. View "In re Adoption of B.H." on Justia Law

The Supreme Court affirmed the decision of the court of appeals remanding this termination of parental rights case to the juvenile court after clarifying the analysis the juvenile court should have applied when interpreting the termination statute, holding that the court of appeals did not err.The juvenile court found multiple grounds for terminating Father's parental rights and then, in compliance with the statutory framework, concluded that termination was in the children's best interests. The juvenile court then addressed the recent legislative mandate set forth in Utah Code 78A-6-507(1) that termination occur only when it is "strictly necessary" to terminate parental rights. On appeal, Father argued that the juvenile court misinterpreted the "strictly necessary" requirement. The court of appeals clarified the analysis the juvenile court should have employed and remanded the case. The Supreme Court affirmed, holding (1) the court of appeals did not err in disavowing the "almost automatically" language in its case law; (2) the court of appeals properly found that the Termination of Parental Rights Act requires that termination be strictly necessary for the best interests of the child; and (3) the juvenile court should revisit the petition and apply the interpretation of the Act set forth in this petition. View "In re B.T.B." on Justia Law

The Supreme Court affirmed the post-conviction court's grant of summary judgment against Defendant's post-conviction claims, holding that Defendant's Atkins v. Virginia, 536 U.S. 304 (2002), claim was not cognizable under the Post-Conviction Remedies Act (PCRA).Defendant was convicted of first-degree murder and sentenced to death. Later, Defendant filed a third state petition for post-conviction relief, including an Atkins claim and twelve additional claims unrelated to Atkins. The post-conviction court concluded that all of Defendant's claims were barred under the PCRA. The Supreme Court affirmed, holding (1) the PCRA did not provide a remedy for Defendant's Atkins claim; and (2) each of Defendant's remaining claims was procedurally barred. View "Archuleta v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the order of the district court granting summary judgment in favor of Maria Luna on Luis Luna's negligence claim, holding that the court of appeals improperly adopted the judicial admission doctrine as applied to a party's deposition testimony.Luis was a passenger in his sister Maria's car when it collided with a vehicle driven by Antonio Arias in a Salt Lake City intersection. Luis sued Maria and Antonio. Maria moved for summary judgment based in part on Luis's testimony that Maria had entered the intersection on a green light. Luis sought to introduce Antonio's testimony that he had the green light, but the district court refused to allow Luis to create a genuine issue of material fact by introducing evidence contradicting his own sworn deposition testimony. The district court granted summary judgment for Maria. The court of appeals affirmed, concluding that Luis's statement should be considered a judicial admission not capable of being rebutted by other evidence. The Supreme Court reversed and remanded the case for further proceedings, holding that a party's deposition testimony is like any other evidentiary admission and can be contradicted with other credible evidence. View "Luna v. Luna" on Justia Law

The Supreme Court held that any power a defendant has to subpoena witnesses at a preliminary hearing is limited by the court's authority to quash unreasonable subpoenas, and that reasonableness inquiry must be informed by the standards that govern preliminary hearings and the rights that the law guarantees for crime victims.The two defendants in this consolidated opinion sought to compel their alleged victims to testify by way of subpoena. The victims, however, had previously participated in interviews about their alleged abuse, and those interviews were introduced as reliable hearsay at the defendants' preliminary hearings. The Supreme Court held that once the State has used a victim's reliable hearsay to make a prima facie showing of probable cause, a subpoena compelling the victim to give additional, live testimony will survive a motion to quash only if the defendant demonstrates that the subpoena is necessary to present specific evidence that is reasonably likely to defeat the showing of probable cause. View "State v. Lopez" on Justia Law

The Supreme Court affirmed the judgment of the trial court against Plaintiff on his medical malpractice claims against LDS Hospital, holding that the trial court did not err in instructing the jury.While undergoing abdominal surgery Plaintiff suffered a cardiac arrest, and his heart did not beat for more than fifteen minutes. Plaintiff suffered brain damage as a result. At trial, LDS Hospital moved for summary judgment on the grounds that the action was time barred. After a bifurcated trial, the jury found that Plaintiff discovered or should have discovered his legal injury more than two years before he commenced the action, and therefore, the action was barred by the statute of limitations. On appeal, Defendant argued that the trial court incorrectly instructed the jury on "discovery of legal injury." The Supreme Court disagreed, holding that, when viewed as a whole, the trial court's instructions to the jury correctly stated the law relevant to discovery of a legal injury. View "Jensen v. IHC Health Services, Inc." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the district court in favor of Plaintiff in this personal injury action, holding that the district court abused its discretion in allowing Plaintiff's expert witness to offer undisclosed causation testimony, and the error was harmful.Plaintiff, who was injured while working on a highway construction site, sued the general contractor for failing to take necessary safety measures to protect workers from highway traffic. The jury found that the general contractor was partially liable for Plaintiff's injury. On appeal, the general contractor argued that the district court erred when it allowed Plaintiff's expert witness to offer an undisclosed opinion on causation. The court of appeals agreed, determining that the error was harmful enough to warrant reversal and a new trial. The Supreme Court affirmed, holding that the testimony was erroneously admitted and that the error was not harmless. View "Arreguin-Leon v. Hadco Construction, LLC" on Justia Law