Justia Utah Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of aggravated murder, desecration of a body, kidnapping, and aggravated kidnapping. Defendant was sentenced to life without parole for his murder conviction. Defendant appealed, arguing, among other things, that it was error for his case to be tried in Cache County with Box Elder County jurors. The Supreme Court affirmed Defendant’s conviction of and sentence for aggravated murder and desecration of a body but reversed and vacated his kidnapping and aggravated kidnapping convictions, holding (1) the trial judge did not abuse his discretion in deciding to hold the trial in Cache County with a jury consisting of residents of neighboring Box Elder County; and (2) because Defendant’s kidnapping and aggravating kidnapping convictions merged, the kidnapping conviction should have been vacated, and Defendant’s aggravated kidnapping conviction should have merged with his aggravated murder conviction. View "State v. Nielsen" on Justia Law

Defendant pled guilty to criminally negligent automobile homicide and driving under the influence of alcohol, reserving his right to challenge the denial of his motion to suppress evidence obtained through a blood draw. Defendant’s blood was drawn after the police were issued eWarrants through the Utah Criminal Justice Information System. On appeal, Defendant argued that because the affidavits submitted by the police in order to obtain the warrants were not supported by an oath or affirmation, as required by both the Utah and United State constitutions, the warrants were unconstitutional. The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress, holding that the affidavits comported with the historical understanding of what constitutes a constitutionally valid “affirmation,” and therefore, the affidavits were constitutionally sufficient to support the issuance of the warrants in this case. View "State v. Gutierrez-Perez" on Justia Law

The State charged Defendant with various crimes, including aggravated burglary and aggravated assault. After the jury was empaneled and sworn and on the second day of trial, the trial judge announced that she was recusing herself and declaring a mistrial. The case was subsequently reassigned for retrial under a new judge. Defendant moved to dismiss the charges against him on the grounds of double jeopardy. The trial court denied the motion, concluding that the mistrial did not act as an acquittal because the mistrial was legally necessary. The Supreme Court reversed, holding (1) the burden to create a record for and sufficiently justify the mistrial fell on the trial court and the State, and, in this case, the legal necessity for a mistrial was not established on the record; and (2) Utah’s constitutional protections against double jeopardy precluded a second trial under such circumstances. View "State v. Manatau" on Justia Law

Christopher Carlton, a Pennsylvania resident, was in a relationship with Shalanda Brown, who was pregnant with Carlton’s child. Unbeknownst to Carlton, Brown traveled to Utah, where she gave birth to a baby girl and relinquished her parental rights to Adoption Center of Choice, Inc. Because no putative father was registered with respect to the child, Adoption Center commenced and adoption proceedings for the child, which were later finalized. Brown, however, had informed Carlton that the child had died. After Brown subsequently told Carlton that the baby was still alive and had been given up for adoption, Carlton filed an amended petition to establish paternity challenging the constitutionality of the Utah Adoption Act and the extent of the rights it affords to putative fathers who wish to contest adoptions in Utah. The district court dismissed Carlton’s petition based on a lack of standing. The Supreme Court reversed in part, holding that the district court erred in (1) denying Carlton leave to amend his petition to cure standing defects to assert the constitutional claims, and thereby, in dismissing Carlton's constitutional claims; and (2) dismissing Carlton’s claim for intentional infliction of emotional distress. Remanded. View "Carlton v. Brown" on Justia Law

Defendant confessed to helping Glenn Griffin commit murder. The State charged both Griffin and Defendant with the crime. The State prosecuted Griffin first and, concerned that Defendant would invoke his privilege against self incrimination and refuse to testify, offered Defendant use immunity. The district judge subsequently issued an order compelling Defendant to testify, but Defendant refused. Thereafter, the State charged Defendant with three counts of obstruction of justice. After a hearing, the magistrate judge refused to bind Defendant over for trial and dismissed the obstruction of justice charges. The court of appeals affirmed, finding that State had failed to present sufficient evidence of intent to obstruct. The Supreme Court reversed, holding that the evidence was sufficient to bind Defendant over for trial for obstruction of justice. Remanded.View "State v. Maughan" on Justia Law

After a jury trial, Defendant was convicted of misdemeanor sexual battery. The court of appeals reversed the conviction and remanded for a new trial, concluding that the district court plainly erred and Defendant's trial counsel was ineffective in allowing the investigative detective's testimony on redirect examination about other allegations of sexual misconduct against him. The Supreme Court reversed, holding that trial counsel was not ineffective in referencing and admitting the Utah R. Evid. 404(b) evidence, and the district court did not commit plain error in allowing the evidence to be presented. In so holding, the Court did not address the State's argument that a gap in the record of a criminal trial should always be interpreted in favor of the State. View "State v. Bedell" on Justia Law

After a jury trial, Appellant was convicted of two counts of aggravated sexual assault and one count of robbery for the 1996 attack and sexual assault of a twenty-three-year-old woman. On appeal, Appellant contended that the statute of limitations had run before the State commenced its prosecution of Appellant and, alternatively, that his right to a speedy trial was violated. The Supreme Court affirmed Appellant's convictions, holding that the State commenced Appellant's prosecution within the applicable statute of limitations and that Appellant's right to a speedy trial was not violated, where, while this case involved an extraordinary delay, the delay was not the fault of the State and Appellant was not prejudiced. View "State v. Young" on Justia Law

After a jury trial, Appellant was convicted of two counts of aggravated sexual abuse of a child and one count of dealing in material harmful to a minor. Defendant appealed, arguing, among other things, that the prosecutor prejudiced the jury by making several improper comments during closing arguments. The Supreme Court vacated Defendant's convictions and remanded for a new trial on all counts, holding (1) Defendant failed to preserve his arguments based on prosecutorial misconduct for appeal; but (2) nevertheless, defense counsel's failure to object to the prosecutor's conduct at trial constituted ineffective assistance of counsel. View "State v. Larrabee" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated murder and two counts of attempted murder. Defendant was sentenced to life without parole for each aggravated murder conviction and three years to life for each attempted murder conviction. The Supreme Court affirmed, holding (1) although the district court erred when it limited and excluded the testimony of the defense's expert witnesses, these errors were harmless; (2) the combined result of these errors did not undermine the Court's confidence in the verdict; and (3) Utah Code 76-3-207.7, which provides the sentencing scheme for first degree felony aggravated murder, is constitutional on its face and was constitutionally applied to Defendant. View "State v. Perea" on Justia Law

After a jury trial, Defendant, who was temporarily staying in the spare bedroom of the victim's father's house, was convicted of aggravated sexual abuse of a child. Defendant's conviction was based on the holding that he occupied a "position of special trust" in relation to the victim under Utah Code 76-5-404.1(4)(h). The district court and court of appeals both held Defendant was an "adult cohabitant" of a parent of the child, which was one of several positions specifically referenced in section 76-5-404.1(4)(h). The Supreme Court vacated Defendant's conviction and remanded, holding (1) the fact that a defendant occupies one of the positions listed in section 76-5-404.1(4)(h) is insufficient, standing alone, to establish the crime of aggravated sexual abuse of a child; (2) for the State to establish aggravated sexual abuse of a child under subsection 4(h), it must prove both that the defendant occupied a "position of authority" over the victim and that the position gave the defendant the ability to "exercise undue influence" over the victim; and (3) because the lower courts did not require the State to establish both elements, Defendant's conviction must be vacated.View "State v. Watkins" on Justia Law