Justia Utah Supreme Court Opinion Summaries

Defendant, a passenger in a vehicle stopped for a traffic infraction, was arrested for possession of methamphetamine after being questioned and searched by a deputy sheriff. Defendant moved to suppress the fruits of the search. The district court denied the motion to suppress, and the court of appeals affirmed. Defendant appealed, arguing that the deputy improperly extended the length of the detention without reasonable suspicion that Defendant was engaged in criminal activity. The Supreme Court affirmed, holding (1) the deputy's questioning of Defendant, during which Defendant admitted to possession of illegal drugs, was proper based on the deputy's reasonable suspicion brought about by the driver's likely impairment and the presence of used drug paraphernalia in plain sight; and (2) the deputy did not improperly extend the duration of Defendant's detention because the deputy's single question to Defendant resulted in only a de minimis extension of the otherwise lawful detention. View "State v. Simons" on Justia Law

Defendant as convicted of aggravated murder and attempted aggravated murder. Defendant's conviction was affirmed on appeal, after which he filed a pro se petition seeking relief under the Post-Conviction Remedies act (PCRA) on the grounds that his trial counsel was ineffective for failing to raise a defense and that his appellate counsel was ineffective for failing to raise a claim of ineffective assistance of counsel on direct appeal. The court granted summary judgment for the State, concluding that Defendant's appellate counsel was not ineffective and that Defendant's ineffective assistance of trial counsel claim was procedurally barred. The Supreme Court reversed, holding (1) disputed issues of material fact precluded summary judgment on Defendant's claim that his appellate counsel was ineffective; and (2) because the Court could not determine whether appellate counsel was ineffective, it could not determine whether Defendant's claim regarding trial counsel was procedurally barred by the PRCA. Remanded for an evidentiary hearing. View "Ross v. State" on Justia Law

After a jury trial, Petitioner was convicted of four counts of sodomy on a child and one count of sexual abuse of a child. The convictions were affirmed on direct appeal. Approximately a dozen years later, Petitioner filed a petition for post-conviction relief. The district court dismissed the petition as procedurally barred under the Post-Conviction Remedies Act's one-year statute of limitations. Petitioner appealed, arguing that applying the one-year statute of limitations to his petition violated the Utah Constitution under the "egregious injustice" exception set forth in Gardner v. State. The Supreme Court (1) affirmed the district court's dismissal of all but one of the claims alleged in Petitioner's petition; but (2) vacated the district court's dismissal of Petitioner's claim for ineffective assistance of counsel during the plea bargaining process, as Defendant may have a newly-recognized claim under the recent U.S. Supreme Court decision, Lafler v. Cooper, which could extend the statute of limitations on his claim. Remanded. View "Winward v. State" on Justia Law

A jury convicted Petitioner of aggravated sexual abuse of a child, sodomy on a child, and attempted rape of a child. The court of appeals affirmed. On certiorari, Petitioner argued that the court of appeals erred in affirming the trial court's ruling that the state was not required to make a separate showing of good cause to admit the alleged victim's recorded statements under Utah R. Crim. P. 15.5. The Supreme Court affirmed the court of appeals, holding (1) a separate showing of good cause to admit a recorded statement is not required under rule 15.5; and (2) rather, good cause is established when the trial court considers all the factors in the rule and determines that the recorded statement is accurate, reliable, and trustworthy, and that admission of the recorded statement is in the interest of justice. View "State v. Nguyen" on Justia Law

Appellant, the biological father of Baby Girl T., challenged the district court's determination of his rights as a birth father and its grant of a motion in limine preventing his presentation of evidence. The court concluded that Appellant did not comply with the provisions of the Utah Adoption Act and therefore waived the right to notice of any judicial proceeding in connection with the adoption of Baby Girl T., as well as the right to refuse to consent to her adoption. It also barred Appellant from presenting evidence that the reason he failed to comply with requirements of the Act was because state employees negligently failed to register his notice of paternity proceedings prior to the birth mother's execution of a consent to adoption. The Supreme Court reversed and remanded, holding that the Act was constitutionally defective as applied to Appellant and deprived him of a meaningful chance to preserve his opportunity to develop a relationship with his child. View "In re Baby Girl T" on Justia Law

Defendant was charged with two counts of assault. He appeared for a jury trial and was subsequently convicted of a misdemeanor assault. Defendant appealed, claiming that his jury was assembled in a manner inconsistent with the requirements of the Equal Protection Clause. The Supreme Court disagreed and affirmed, holding (1) Defendant failed to timely preserve his Batson challenge, (2) the trial court did not err when it did not make findings or rule on the Batson challenge, and (3) Defendant's ineffective assistance of counsel claim based on his counsel's failure to timely preserve his Batson challenge failed under Washington v. Strickland. View "State v. Harris" on Justia Law

Defendant entered into a plea agreement in 2005 in which the State promised to not oppose a motion to reduce his convictions. Defendant later filed a motion to reduce his convictions after successfully completing his probation, as required by statute. During his probation, however, the statute governing reduction of convictions was amended to bar reduction for crimes like Defendant's that triggered the sex offender registration requirement. The district court applied the amended statute retroactively to deny Defendant's motion. The Supreme Court reversed and remanded for reconsideration of Defendant's motion under the version of the statute in effect when he was initially sentenced, holding that the district court erred in applying the amended statute to Defendant's motion to reduce his convictions. View "State v. Johnson" on Justia Law

In 1985, Appellant was convicted of first degree murder and sentenced to death. In 2006, Appellant filed a successive postconviction petition for relief. In 2009, the district court dismissed Appellant's petition, holding (1) all claims were procedurally barred except the claim of ineffective assistance of postconviction counsel in the first Post Conviction Relief Act (PCRA) proceedings; and (2) Appellant's ineffective assistance of counsel claim was not timely brought. The Supreme Court affirmed the dismissal, holding (1) the district court did not abuse its discretion in denying Appellant's request for a six-month stay of proceedings; (2) the district court was correct in determining that all of Appellant's claims were procedurally barred except the claim of ineffective assistance of postconviction counsel; and (3) because Appellant did not make a showing of ineffective assistance, the Court did not need to consider whether the claim was time barred or whether Appellant had either a statutory or constitutional right to effective assistance of postconviction counsel. View "Carter v. State" on Justia Law

Defendant was convicted of aggravated sexual abuse of a child, a first-degree felony, and dealing in material harmful to a minor, a second-degree felony. Defendant appealed his convictions to the court of appeals, asserting he should be granted a new trial because his trial counsel was ineffective. Specifically, Defendant contended that trial counsel did not properly investigate or exploit discrepancies in the victim's statements about whether the abuse occurred in 2002 or 2003. The court of appeals agreed and granted a new trial on both charges. The State conceded that Defendant's counsel acted ineffectively in defending the sexual abuse conviction, but petitioned for writ of certiorari on the harmful materials conviction. The Supreme Court affirmed the court of appeals' conclusion that Defendant was entitled to a new trial on the harmful materials conviction, holding that trial counsel's failure to press the time discrepancy was prejudicial. Remanded. View "State v. Moore" on Justia Law

The State filed a petition that charge D.B. as a principal with theft and criminal trespass for entering a construction site and removing a pair of bolt cutters. The juvenile court adjudicated D.B. a delinquent as an accomplice on both counts. The court of appeals affirmed. D.B. filed a petition for writ of certiorari, claiming that he did not receive adequate Sixth Amendment notice that he may be adjudicated delinquent as an accomplice for the charges. The Supreme Court reversed the delinquency adjudication on the criminal trespass charge but affirmed it on the theft charge, holding (1) D.B. received constitutionally adequate notice through trial testimony that he faced accomplice liability for theft; but (2) the juvenile court adjudicated D.B. delinquent as an accomplice for criminal trespass without notice. Remanded. View "D.B. v. State" on Justia Law