Justia Utah Supreme Court Opinion Summaries

Defendant was convicted of sexual abuse of a child. At trial, the court admitted evidence of two prior uncharged sexual assaults by Defendant. On appeal, Defendant challenged the admissibility of that evidence under Utah R. Evid. 404(b), asserting either that it was not offered for a non-character purpose or that its probative value was substantially outweighed by a risk of unfair prejudice. The court of appeals deemed the evidence admissible for two non-character purposes and affirmed. The Supreme Court (1) reversed the conviction, holding (i) the court of appeals erred in affirming the admissibility of evidence of Defendant's uncharged misconduct offered to prove his specific criminal intent, which was not a legitimately disputed issue at trial; and (ii) the State's evidence was not admissible to prove Defendant acted in conformity with a plan to entice and abuse young men, as the evidence did not demonstrate that Defendant entered a preconceived, overarching design to commit the acts in question; and (2) remanded for a new trial, leaving the door open for the State to offer its evidence on grounds different from those adopted by the trial court or court of appeals. View "State v. Verde" on Justia Law

Defendant was charged with possession of methamphetamine and drug paraphernalia after a search of his motel room. The district court declined to bind Defendant over for trial at a preliminary hearing, concluding that every reasonable inference from the evidence was that Defendant did not know of the presence of the drug residue and paraphernalia, and therefore, without evidence of an intent to exercise control, there could be no inference of possession of drug residue or paraphernalia. A divided court of appeals affirmed. The Supreme Court reversed, holding (1) the magistrate's and court of appeals majority's concerns with the evidence were insufficient to foreclose a finding of probable cause; (2) the magistrate and court of appeals overstepped their bounds in favoring Defendant's inference that he "didn't know the drugs were there" as stronger than the prosecution's alternative; and (3) the lack of evidence concerning the exclusivity of Defendant's control and access to the motel room did not defeat the prosecution's showing of probable cause. Remanded with instructions to bind Defendant over for trial. View "State v. Ramirez" on Justia Law

Defendant was convicted of aggravated assault and criminal mischief. Defendant appealed his convictions and submitted a hybrid Anders/merits brief. Upon review of Defendant's pro se filings and his counsel's Anders brief, the court of appeals identified only one meritorious issue: the claim that the jury instructions misstated the law regarding aggravated the assault. The court of appeals then affirmed Defendant's conviction based on its interpretation of the aggravated assault statute. On certiorari before the Supreme Court, Defendant challenged the court of appeals' interpretation of the aggravated assault statute and advanced other claims foreclosed by the court of appeals' statutory interpretation. Court affirmed on alternate grounds, holding (1) the court of appeals erred in its interpretation of the statute; but (2) although counsel's failure to object to the instructions resulted in deficient performance, there was no prejudice to Defendant sufficient to justify reversal of the verdict. View "State v. Hutchings" on Justia Law

The Supreme Court granted the State's petition for interlocutory review to address whether a court may grant a criminal defendant's request to waive a jury trial over the prosecution's objection. The district court granted Defendant's waiver of a jury trial in favor of a bench trial because of the court's perceived due process concerns. On appeal, the State argued that the district court erred because it disregarded the clear provisions of Utah. R. Crim. P. 17(c) that require the consent of the prosecution before a defendant may waive a jury trial. The Supreme Court reversed, holding (1) under Rule 17(c), Defendant may not waive a jury trial without the State's consent; and (2) Defendant's due process rights were not implicated in this case. Remanded for a jury trial. View "State v. Greenwood" on Justia Law

Defendant was charged with aggravated murder and aggravated burglary. After being tried and convicted on both charges, he was sentenced to death. On appeal, Defendant raised numerous arguments concerning his convictions, the imposition of the death penalty, and Utah's death penalty scheme. Defendant's arguments included (1) jury issues, (2) evidence and arguments in the guilt phase of the trial, (3) challenges regarding the death penalty exemption hearing, (4) evidence and arguments in the penalty phase, (5) constitutional challenges to Utah's death penalty scheme, and (6) claims of cumulative error. The Supreme Court rejected each of Defendant's arguments and affirmed Defendants' convictions and sentence. View "State v. Maestas" on Justia Law

A jury convicted Defendant of aggravated robbery. The jury found that Defendant was subject to a one-year enhancement of his sentence because a dangerous weapon was used in the course of the robbery. The court of appeals affirmed. Defendant appealed, contending that the State failed to prove he had knowledge of the principal's possession of a dangerous weapon. The Supreme Court affirmed the conviction of aggravated robbery with a one-year penalty enhancement after clarifying the mental state required for the dangerous weapon aggravator in Utah Code 76-6-302(1)(a), holding (1) because the legislature has made no indication that it is a strict liability offense, the statutory aggravator requires the culpable mental state of recklessness; but (2) Defendant's claims on appeal did not require reversal because he did not demonstrate that the errors caused him prejudice. View "State v. Jimenez" on Justia Law

Plaintiffs brought suit against a law firm and its attorneys for their role in executing civil discovery orders. The orders authorized entry into Plaintiffs' home to seize electronic files from Plaintiffs' computer and other electronic devices. Plaintiffs raised several causes of action based largely on the theory that the execution of the civil discovery orders constituted an illegal warrantless search. The district court granted Defendants' motion for judgment on the pleadings, and the court of appeals affirmed. The Supreme Court affirmed on alternate grounds, holding (1) the judicial proceedings privilege extends to attorneys' conduct in representing their clients; and (2) as applied in this case, the privilege barred all of Plaintiffs' claims. View "Moss v. Parr Waddoups Brown Gee & Loveless" on Justia Law

Defendant Eric Butt was convicted of distributing harmful materials to a minor when he mailed rudimentary nude drawings of himself to his five-year-old daughter. On appeal, Butt argued that the evidence was insufficient to support his conviction because the State presented nothing more than the drawings themselves. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the jury's conclusion that Defendant "distributed" the material to a minor under Utah Code 76-10-1206(1); (2) the evidence was sufficient to support the jury's conclusion that the material was "harmful" as defined by Utah Code 76-10-1201(5)(a); and (3) Defendant's argument that the jury used the incorrect community standard was not preserved for appeal. View "State v. Butt" on Justia Law

Petitioner David Gregg was convicted of rape, a first-degree felony. The trial court sentenced Gregg to an indeterminate term of five years to life. The court of appeals affirmed the conviction. Gregg subsequently filed an amended petition for post-confiction relief, alleging ineffective assistance of trial and appellate counsel. The district court dismissed all of Gregg's claims as procedurally barred under the Post-Conviction Remedies Act (PCRA) because of a procedural error on behalf of the court clerk. The Supreme Court vacated Gregg's conviction, holding (1) Gregg qualified for an exception to the procedural bar because the Court would not hold Gregg accountable for the clerk of court's procedural error; and (2) Gregg received ineffective assistance of trial and appellate counsel. Remanded for a new trial. View "Gregg v. State" on Justia Law

Wolfgango Ruiz pled guilty to one count of attempted sexual abuse of a child, a third degree felony. Prior to his sentencing, Ruiz made a request to withdraw his plea on the ground that his original defense counsel had not informed him of the immigration consequences of a felony conviction. District Court Judge Fuchs initially granted Ruiz's motion, but upon a motion to reconsider, Judge Skanchy reversed the order that permitted Ruiz to withdraw his plea. The court of appeals reversed Judge Skanchy's ruling and reinstated Judge Fuch's order based on Judge Skanchy's failure to state the basis for his ruling on the record and the principal that motions to withdraw guilty pleas should be liberally granted. The Supreme Court reversed, holding (1) the court of appeals err in vacating Judge Skanchy's ruling because the basis for the ruling was apparent on the record; and (2) recent amendments to the Plea Withdrawal Statute superseded prior case law stating that presentence motions to withdraw guilty pleas should be liberally granted. Remanded. View "State v. Ruiz" on Justia Law