Justia Utah Supreme Court Opinion Summaries

Appellant was convicted of two counts of aggravated murder and related crimes. The Supreme Court affirmed. Thereafter, Appellant filed a petition for relief under the Post-Conviction Remedies Act (PCRA), claiming that newly discovered evidence in the form of testimony from two new witnesses would exonerate him and that the State violated his due process rights by knowingly introducing perjured testimony and fabricating evidence at trial. The district court dismissed Appellant’s PCRA claims. The Supreme Court affirmed, holding (1) because Appellant failed to demonstrate that no reasonable jury could enter a judgment of conviction in light of the new testimony, Appellant’s newly discovered evidence claims failed on their merits; (2) Appellant’s due process claims were procedurally barred because they could have been but were not brought at trial or on appeal; and (3) the district court did not abuse its discretion in denying Appellant’s motions for discovery and to amend his PCRA pleadings. View "Pinder v. State" on Justia Law

Defendant was seventeen and a half when he murdered a staff member of the residential treatment center for youth where he was temporarily residing. Defendant pleaded guilty to aggravated murder. The jury, after considering the mitigating circumstances inherent to Defendant’s youth, nevertheless sentenced him to life imprisonment without the possibility of parole. Defendant appealed, bringing numerous constitutional challenges to his sentence and alleging that his counsel provided ineffective assistance during the sentencing proceeding. The Supreme Court affirmed, holding that Defendant’s sentence was constitutional and that Defendant failed to demonstrate that he received ineffective assistance of counsel. View "State v. Houston" on Justia Law

Appellant was seventeen and one-half years old when he murdered the victim in this case. Appellant pleaded guilty to aggravated murder, and the parties proceeded to a sentencing hearing before a jury. Following the sentencing hearing, eleven of the twelve jurors voted to sentence Appellant to life imprisonment without the possibility of parole. Appellant appealed, bringing several constitutional challenges to his sentence under Utah R. Crim. P. 22(e). The Supreme Court affirmed the jury’s sentence, holding (1) Appellant’s sentence was constitutional; and (2) Appellant failed to demonstrate that he received ineffective assistance of counsel. View "State v. Houston" on Justia Law

A police officer filed a citation issued against Appellant for an open container offense in justice court, thus initiating a criminal case against Appellant. After Appellant failed to appear or forfeit bail on her justice court charge, prosecutors filed an information in district court charging Appellant with DUI, an alcohol-restricted driver offense, and an open container violation. Appellant subsequently paid her justice court fine, thus accepting a conviction in justice court on the open container offense. Despite the justice court conviction, prosecutors moved forward on the information filed in the district court. Defendant moved to dismiss. The district court (1) dismissed the open container charge, determining that the Double Jeopardy Clause prohibited a serial prosecution on that charge; but (2) denied Appellant’s motion to dismiss the other two charges, concluding that the charges were not precluded by Utah Code 76-1-403, which adopts a principle of criminal claim preclusion for offenses arising out of a “single criminal episode.” The Supreme Court affirmed the denial of Appellant’s motion to dismiss the remaining two charges, holding that the preclusion principle in section 403 was inapplicable in this case because there was no “prosecuting attorney” involved in Appellant’s first offense. View "State v. Ririe" on Justia Law

Since 1971, a monument displaying a representation of the Ten Commandments tablets has stood in a park owned by the City of Pleasant Grove. In 2003, Summum, a corporation sole and church, offered to donate and erect a “Seven Aphorisms” monument in the park that was similar to the Ten Commandments monument. The City declined Summum’s offer. After unsuccessfully suing in federal court, Summum sued in federal court. The United States Supreme Court concluded that the placement of a monument on public property was a form of government speech not regulated by the Free Speech Clause. Summum subsequently sued in state court, alleging that the City had violated the religious liberty clause of the state Constitution and seeking an injunction requiring the City to display the Seven Aphorisms monument. The district court granted summary judgment for the City. The Supreme Court affirmed, holding that the religious liberty clause of the Utah Constitution does not require the district court to force the City to permanently display the Seven Aphorisms monument because the neutrality test adopted in Soc’y of Separationists v. Whitehead to determine whether a government action amounts to an unconstitutional appropriation of public money for religious exercise does not apply in the context of public monuments. View "Summum v. Pleasant Grove City" on Justia Law

After a jury trial, Defendant was convicted of first-degree rape. The Supreme Court reversed, holding (1) trial counsel was ineffective for failing to object to a jury instruction misstating the requirement of mens rea as applied to the elements of first-degree rape; and (2) the statutory standard for nonconsent under Utah Code 76-5-406 does not establish the sum and substance of all circumstances amounting to nonconsent but simply prescribes the circumstances in which the legislature forecloses a jury finding of consent as a matter of public policy. The Court also clarified and the standard for granting a defendant’s request for a victim’s medical records under Utah R. Crim. P. 14(b). View "State v. Barela" on Justia Law

Defendant entered a conditional guilty plea to five charges of sexual exploitation of a minor. The charges arose from the discovery of child pornography on Defendant’s laptop computer. Defendant appealed, challenging several of the district court’s pretrial rulings, many of them related to the propriety of law enforcement’s use of the Wyoming Toolkit, a computer program and database used to identify child pornography shared over the Internet with peer-to-peer (P2P) file sharing networks. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress the evidence of child pornography found on Defendant’s computer, as the government’s use of the Wyoming Toolkit to identify child pornography in files shared on a P2P network is not a search; (2) the district court did not abuse its discretion in denying Defendant’s motion to compel discovery of the Wyoming Toolkit; (3) the classifications created by Utah’s sexual exploitation of a minor statute are constitutional, and Defendant lacked standing to challenge the constitutionality of the statute’s purported disparate treatment of prosecutors and criminal defense attorneys; and (4) the district court did not abuse its discretion in denying Defendant’s motion in limine to exclude expert testimony related to the Wyoming Toolkit. View "State v. Roberts" on Justia Law

After a jury trial, Defendant was convicted of murder, aggravated robbery, and unlawful distribution of a controlled substance. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion when it admitted Y-STR DNA evidence linking Defendant to the murder weapon; (2) the trial court did not err when it refused to admit the entire transcript or video of Defendant’s second police interview after a State witness testified to portions of the interview at trial; (3) defense counsel did not render ineffective assistance in his cross-examination of one of the detectives who conducted the second interview; (4) the trial court did not err when it admitted an officer’s testimony about the frequency of drug-related crimes; (5) the State did not engage in prosecutorial misconduct during closing argument; (6) the evidence was sufficient to sustain convictions for murder and aggravated robbery; and (7) Defendant failed to demonstrate cumulative error that undermined confidence in the verdict. View "State v. Jones" on Justia Law

At issue in this case was the applicability of the “attenuation” exception to the exclusionary rule to a fact pattern involving an unlawful detention leading to the discovery of an arrest warrant followed by a search incident to arrest. Defendant in this case entered a conditional plea to drug-related charges, reserving the right to appeal the denial of his motions to suppress and reconsider. The court of appeals affirmed under the attenuation exception to the exclusionary rule. After noting that the lower courts are in “disarray” in their application of the attenuation doctrine to the outstanding warrant scenario and the lack of direction from the U.S. Supreme Court on the matter, the Supreme Court concluded (1) the attenuation exception is limited to cases involving intervening acts of a defendant’s free will, as in a confession or consent to search; and (2) because this case involved no independent act of a defendant’s free will, the attenuation doctrine was not implicated, and Defendant was entitled to suppression of the evidence secured in the search incident to his arrest. View "State v. Strieff" on Justia Law

After a jury trial, Defendant was found guilty of one count of murder and two counts of aggravated robbery. Upon sentencing Defendant, the trial court failed to comply with Utah R. Crim. P. 22(c)(1) by not informing Defendant of his right to appeal and of the thirty-day deadline for filing a notice of appeal. Over two years later, Defendant filed a motion seeking reinstatement of his right to appeal. The trial court denied the motion. The court of appeals reversed, concluding that because neither the trial court nor defense counsel informed Defendant of the thirty-day deadline, Defendant had a valid claim for reinstatement of the right to appeal. The Supreme Court reversed, holding that claims for reinstatement of the right to appeal are subject to harmless error review, and the court of appeals in this case erred by declining to apply harmless error analysis. Remanded. View "State v. Collins" on Justia Law