Articles Posted in Civil Rights

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The Supreme Court reversed the judgment of the district court granting Defendants’ motion to suppress the result of a search executed pursuant to a search warrant. The warrant was signed by a magistrate and executed by the police. Defendants moved under the state and federal constitutions to suppress the result of the search, challenging the magistrate’s probable cause determination. The district court found that there was no probable cause but that the federal good faith exception to the exclusionary rule applied. When Defendants again moved to suppress, the court suppressed the evidence under the state constitution, concluding that there was no state good faith exception to the exclusionary rule. The Supreme Court reversed without reaching the questions of whether the court has recognized an exclusionary rule under the Utah Constitution or whether there should be a good faith exception to such a rule, holding that there was a substantial basis for the magistrate’s probable cause determination. View "State v. Rowan" on Justia Law

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The Supreme Court dismissed Appellant’s appeal of the denial of his motion to withdraw his guilty plea to aggravated murder and other offenses and no contest plea to three counts of attempted aggravated murder. The district court denied the motion on the ground that the Plea Withdrawal Statute, Utah Code 77-13-6, provides that a “request to withdraw a plea of guilty or no contest…shall be made by motion before sentence is announced.” On appeal, Defendant challenged the constitutionality of the statute and contended that he received ineffective assistance of counsel when he entered the plea agreement. The Supreme Court held (1) the jurisdictional bar imposed by the Plea Withdrawal Statute does not deprive a defendant of his constitutional right to an appeal; and (2) Appellant did not timely move to withdraw his pleas, and therefore, Appellant forfeited his right to direct appeal. View "State v. Allgier" on Justia Law

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The Supreme Court affirmed the judgment of the juvenile court adjudicating D.G. and R.G. delinquent for committing aggravated sexual assault. The juvenile court denied the motions filed by D.G. and R.G. to suppress their post-Miranda statements regarding the sexual assault to a detective during an interview, and both interviews with the detective regarding the sexual assault were introduced at trial. D.G. and R.G. appealed, arguing that the juvenile court erred in denying the motion to suppress their post-Miranda statements. The Supreme Court affirmed, holding (1) the Miranda warnings given to D.G. and R.G. were sufficient according to the standards set by this court and the United States Supreme Court; and (2) both D.G. and R.G. knowingly and voluntarily waived their Miranda rights. View "In re R.G." on Justia Law

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The Supreme Court affirmed the district court’s dismissal of Plaintiffs’ putative class action lawsuit in which they alleged that Salt Lake City unjustly enriched itself by fining them for failing to use a parking meter at a time when there were no longer any parking meters in the City - only pay stations - but the City had not yet prohibited parking without paying at a pay station. Plaintiffs also alleged that the City’s notices violated due process. The district court granted the City’s motion to dismiss. The Supreme Court affirmed, holding (1) the City’s notices were sufficient to apprise Plaintiffs of both their right to challenge their parking tickets and their opportunity for a hearing on that challenge; and (2) because Plaintiffs did not exhaust their legal remedies before seeking to challenge their tickets through an equitable action Plaintiffs failed to state an equitable enrichment claim. View "Bivens v. Salt Lake City" on Justia Law

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The Supreme Court affirmed Defendant’s conviction of four counts of aggravated sexual abuse of a child and sentence of a composite term of thirty years to life in prison. The court held (1) to the extent that Defendant’s arguments that the district court erred in admitting expert testimony by a forensic interviewer at the Children’s Justice Center, they lacked merit; (2) the district court did not violate Defendant’s constitutional right to present a complete defense when it excluded evidence of a witness’s supposed prior false accusations of sexual misconduct; and (3) there was no abuse of discretion in the district court’s sentencing decision. View "State v. Martin" on Justia Law

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The Supreme Court reversed the district court’s order granting Defendant’s motion to suppress evidence obtained incident to his arrest. The district court concluded that the law enforcement officer who stopped Defendant’s vehicle for an improper lane change violated Defendant’s Fourth Amendment rights when he asked to see Defendant’s identification and ran a warrants check without reasonable suspicion that Defendant had committed or was about to commit a crime. The Supreme Court disagreed, holding (1) to promote officer safety, the Fourth Amendment does not prevent an officer from asking a passenger to produce identification and running a warrants check so long as that does not unreasonably prolong the duration of the stop; and (2) in this case, the officer’s seconds-long extension of the lawful traffic stop did not unreasonably prolong the detention. View "State v. Martinez" on Justia Law

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The Supreme Court vacated Petitioner’s conviction for dealing materials harmful to minors, holding that trial counsel was ineffective in failing to assert a free speech First Amendment defense and that such a defense would have succeeded if it had been raised. The conviction stemmed from the interception of drawings Petitioner had sent to his five-year-old daughter from jail depicting Petitioner as naked and holding his daughter in the air. The district court granted summary judgment to the State on Petitioner’s petition for post-conviction relief, concluding that Petitioner suffered no prejudice because his First Amendment defense lacked merit. The Supreme Court reversed and vacated Petitioner’s conviction, holding that Petitioner’s drawing was not overtly sexual or sexually suggestive, and therefore, Petitioner’s First Amendment defense was viable. View "Butt v. State" on Justia Law

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The plain language of Utah Code 41-6a-517, does not require a showing of impairment, and the statute does not violate the federal or state constitutions. Defendant was charged under section 41-6a-517 with operating a motor vehicle with a metabolite of a controlled substance in his body. The district court denied Defendant’s motion to dismiss. Defendant entered a plea of no contest, reserving his right to appeal. The Supreme Court affirmed, holding (1) an individual violates section 41-6a-517 when he or she operates or is in actual physical control of a motor vehicle with any measurable controlled substance or metabolite of a controlled substance in the person’s body; and (2) the statute does not violate the Eighth or Fourteenth Amendments of the United States Constitution or the uniform operation of laws provision of the Utah Constitution. View "State v. Outzen" on Justia Law

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The Supreme Court reversed the district court’s order granting Defendant’s motion to suppress the evidence obtained after a law enforcement officer stopped a vehicle for a traffic violation and searched Defendant, a passenger, incident to his arrest on an outstanding arrest warrant. The district court had concluded that the trooper had violated Defendant’s Fourth Amendment rights when he asked to see Defendant’s identification and ran a warrants check without reasonable suspicion that Defendant had committed or was about to commit a crime. The Supreme Court disagreed, holding that the officer’s seconds-long extension of the lawful traffic stop to request Defendant’s identification did not unreasonably prolong the detention and that officer safety concerns justified the “negligibly burdensome extension of the traffic stop[.]” View "State v. Martinez" on Justia Law

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Defendant was convicted of possessing a shank in prison. Defendant appealed, arguing (1) the trial court erred in denying his motion to dismiss because the State lost or destroyed a video recording of the discovery of the shank, and (2) his counsel was ineffective in stipulating to the due process analysis applicable to claims regarding evidence destroyed or lost by the State. The Supreme Court affirmed, holding (1) under the due process analysis set forth in State v. Tiedemann, Defendant’s due process rights were not violated; and (2) Defendant’s counsel did not provide ineffective assistance. View "State v. Mohamud" on Justia Law