Justia Utah Supreme Court Opinion Summaries

In 1988, a defendant was convicted of first-degree murder and sentenced to death. Decades later, after exhausting his appeals, he was diagnosed with vascular dementia, a progressive neurocognitive disorder that impairs memory and cognitive function. When the State sought an execution warrant in early 2024, the defendant filed a petition asserting that his dementia rendered him incompetent to be executed under the Eighth Amendment, which prohibits executing individuals who cannot rationally understand the reason for their execution.The Third District Court, Salt Lake County, held an evidentiary hearing with multiple expert witnesses. Although it was uncontested that the defendant suffered from vascular dementia and had experienced cognitive decline, the court found him competent to be executed, concluding he retained a rational understanding of the reason for his death sentence. The defendant appealed and requested a stay of execution, which the district court denied. Subsequently, he filed a petition for reevaluation, supported by new expert reports and observations indicating further rapid decline and an inability to understand the connection between his crime and punishment. The district court denied this petition, finding no substantial change in circumstances and no significant question about competency.The Supreme Court of the State of Utah reviewed both the appeal of the first competency order and the denial of the reevaluation petition. The court held that a successive competency petition must make a prima facie showing of a substantial change of circumstances and raise a significant question about competency. The district court erred by weighing rebuttal evidence at this threshold stage and by concluding the defendant failed to meet the statutory requirements. The Supreme Court reversed the order denying reevaluation and remanded for further proceedings. The appeal of the first competency order and one petition for extraordinary relief were deemed moot. View "State v. Menzies" on Justia Law

A group of landowners in Summit County, Utah, challenged a proposed ballot measure to incorporate a new municipality called West Hills. The sponsor of the incorporation, Derek Anderson, had modified the proposed boundaries after the statutory deadline for landowners to request exclusion from the new municipality had passed. As a result, certain landowners whose properties were added late were unable to seek exclusion, even though similarly situated landowners had previously been allowed to do so.The landowners filed suit in the Third District Court, Silver Summit, arguing that the Municipal Incorporation Code, as applied, violated the Uniform Operation of Laws Clause of the Utah Constitution. The district court granted summary judgment for the landowners, finding the code unconstitutional as applied and invalidating the certification of the West Hills ballot measure. The court determined that the plaintiffs were “specified landowners” who would have been entitled to exclusion if their properties had been added earlier, and that the legislature’s interest in certainty did not justify the disparate treatment.The sponsor then filed an emergency petition for extraordinary relief with the Supreme Court of the State of Utah, seeking to overturn the district court’s order before the upcoming election. The Utah Supreme Court, after expedited briefing and oral argument, denied the petition for extraordinary relief. The court held that, under the unique circumstances, it would not exercise its discretion to issue a writ due to the potential disruption and confusion in the election process, including the risk of voter suppression and interference with electioneering efforts. The denial was without prejudice to the sponsor’s ability to pursue an appeal or interlocutory review of the district court’s order. View "Anderson v. Bates" on Justia Law

In this case, Utah voters passed Proposition 4 in 2018, a citizen initiative designed to reform the state’s redistricting process and address partisan gerrymandering. Before the next redistricting cycle, the Utah Legislature repealed Proposition 4 and replaced it with Senate Bill 200 (S.B. 200), which eliminated the key reforms established by the initiative. Several organizations and individuals challenged this legislative action, arguing that the repeal violated Utahns’ constitutional right to alter or reform their government through the initiative process.The Third District Court initially dismissed the plaintiffs’ claim that the Legislature’s repeal of Proposition 4 was unconstitutional. On interlocutory appeal, the Supreme Court of Utah held that the people’s right to reform their government via initiative is constitutionally protected and remanded the case for further proceedings. On remand, the district court granted summary judgment to the plaintiffs, finding that S.B. 200 unconstitutionally impaired the reforms enacted by Proposition 4 and was not narrowly tailored to serve a compelling state interest. The court declared Proposition 4 to be the law, enjoined the use of the 2021 Congressional Map enacted under S.B. 200, and established a remedial process for creating a compliant map. The Legislature’s request to stay the injunction on the 2021 map during the remedial process and any appeals was denied by the district court.The Supreme Court of the State of Utah reviewed the Legislature’s emergency petition for extraordinary relief, which challenged only the district court’s denial of the stay. The Supreme Court held that the Legislature had not shown the district court abused its discretion in denying the stay, as their arguments focused on the remedial process rather than the legal standard for granting a stay. The petition for extraordinary relief was therefore denied. View "State Legislature v. League of Women Voters" on Justia Law

In 1988, a man was convicted of first-degree murder and sentenced to death. Decades later, after exhausting his appeals, he was diagnosed with vascular dementia, a progressive neurocognitive disorder that impairs memory and cognitive function. When the state sought an execution warrant in early 2024, he petitioned the court, arguing that his dementia rendered him incompetent to be executed under the Eighth Amendment, which prohibits executing individuals who cannot rationally understand the reason for their execution.The Third District Court in Salt Lake County held an evidentiary hearing, where multiple experts agreed he had vascular dementia and noted a decline in his cognitive abilities. However, the court found he was still competent to be executed, concluding he could rationally understand the reason for his death sentence. The defendant appealed and requested a stay, which was denied. Subsequently, he filed a new petition for reevaluation, supported by recent expert reports and observations indicating a rapid decline and new inability to understand the connection between his crime and punishment. The district court denied this petition, finding no substantial change in circumstances or significant question about his competency, and issued an execution warrant.The Supreme Court of the State of Utah reviewed the case. It held that, under Utah law, a successive petition to reopen competency proceedings must make a prima facie showing of a substantial change in circumstances and raise a significant question about competency. The court found that the district court erred by weighing rebuttal evidence at the threshold stage and by concluding the new petition did not meet the statutory requirements. The Supreme Court reversed the order denying reevaluation, vacated the execution warrant, and remanded for further proceedings. The appeal of the initial competency order and one extraordinary writ petition were deemed moot. View "State v. Menzies" on Justia Law

A 34-year-old man engaged in a months-long sexual relationship with a 16-year-old girl, whom he met online. The relationship involved sexual encounters, the exchange of nude photographs, and the provision of marijuana and alcohol to the minor. The man used online messaging applications to communicate and arrange meetings. The investigation began after the girl reported the relationship to police, but she could not provide identifying information about the man beyond his online aliases. State detectives, working as part of a federal task force, requested that federal officers use federal administrative subpoenas to obtain electronic records from service providers, which ultimately identified the suspect.The Second District Court in Davis County denied the defendant’s motion to suppress the electronic records, finding that the evidence was lawfully obtained through federal subpoenas. The court also admitted evidence from the defendant’s Summit County residence, including items corroborating the girl’s account. At trial, the jury convicted the defendant on multiple counts, including human trafficking of a child, sexual exploitation of a minor, and distribution of a controlled substance. The court partially granted a post-trial motion to arrest judgment but left the most serious convictions intact. The defendant appealed.The Supreme Court of the State of Utah held that Utah’s Electronic Information or Data Privacy Act (EIDPA) does not require suppression of evidence lawfully obtained by federal officers and shared with state officers, and that the Utah Constitution was not violated by the use of such evidence. The court vacated the conviction for human trafficking of a child, holding that the statute requires proof that something of value was actually given or received in exchange for a sexual act, not merely offered. The court affirmed the convictions for sexual exploitation of a minor and distribution of a controlled substance, and found that any error in admitting certain evidence was harmless. View "State v. Andrus" on Justia Law

Terry Tischmak was married to a resident student attending Salt Lake Community College in Utah during the 2013 and 2014 tax years. Although he lived and worked in Wyoming, he and his wife filed their federal taxes jointly. Utah's Domicile Statute deems individuals domiciled in Utah for tax purposes if they or their spouse are resident students at a state institution. Consequently, the Utah State Tax Commission determined that Tischmak owed state income taxes for those years.The Utah State Tax Commission audited Tischmak and issued a Notice of Deficiency for the 2013 and 2014 tax years. Tischmak appealed, arguing that he should not be subject to Utah's income tax because he resided in Wyoming. After a formal hearing, the Commission upheld its decision, citing the Domicile Statute, which considers a person domiciled in Utah if their spouse is a resident student. The Commission did not address Tischmak's constitutional arguments, noting it lacked the authority to do so.The Utah Supreme Court reviewed the case and upheld the Tax Commission's decision. The court found that the Domicile Statute did not violate the federal right to travel, the Utah Constitution’s Due Process Clause, or the Uniform Operation of Laws Provision. The court also determined that the statute did not violate the U.S. Constitution’s Due Process Clause or the dormant Commerce Clause. The court concluded that the statute was constitutional and that Tischmak was subject to Utah's income tax for the years in question. View "Tischmak v. Tax Commission" on Justia Law

A thirty-four-year-old man engaged in a months-long sexual relationship with a sixteen-year-old girl, whom he met online. The relationship involved repeated sexual encounters, the exchange of nude photographs and explicit video calls, and the provision of marijuana and offers of other gifts. The girl reported the relationship to police, who struggled to identify the perpetrator due to his use of pseudonyms and anonymous messaging apps. State detectives, working as part of a federal task force, requested that federal officers use federal administrative subpoenas to obtain electronic records from service providers, which ultimately led to the identification and arrest of the defendant. A search of his home yielded physical evidence linking him to the victim.The Second District Court in Davis County denied the defendant’s motion to suppress the electronic records obtained via federal subpoenas, rejected his motions to arrest judgment and for a directed verdict on several charges, and admitted evidence of uncharged conduct from another county. The jury convicted the defendant on all counts, and the court partially granted a post-trial motion to arrest judgment, but left convictions for human trafficking of a child and sexual exploitation of a minor intact. The defendant appealed.The Supreme Court of the State of Utah held that Utah’s Electronic Information or Data Privacy Act (EIDPA) does not require suppression of evidence lawfully obtained by federal officers under federal law and then shared with state officers, and that the Utah Constitution does not mandate exclusion of such evidence. The court vacated the conviction for human trafficking of a child, holding that the statute requires proof that something of value was actually given or received in exchange for a sexual act, not merely offered. The court affirmed the convictions for sexual exploitation of a minor and distribution of a controlled substance, and found no reversible error in the admission of evidence related to uncharged conduct. View "State v. Andrus" on Justia Law

Kyli Jenae Labrum was charged with ten counts of rape and one count of forcible sexual abuse after allegedly engaging in a sexual relationship with T.S., a sixteen-year-old boy. The State's case relied on two theories of nonconsent: a special trust theory and an enticement theory. At the preliminary hearing, the stand-in prosecutor only argued the special trust theory, which the magistrate judge rejected, ruling that the State had not shown the relationship was nonconsensual. The State then moved to reduce the charges to a lesser offense but later decided to pursue the original charges, filing a motion for reconsideration and then refiling the charges with both theories of nonconsent.The magistrate judge denied the motion for reconsideration and dismissed the refiled charges, ruling that the State's actions were procedurally inappropriate and constitutionally barred under the Utah Constitution’s Due Process Clause. The State appealed, arguing that the magistrate erred in its determination.The Utah Supreme Court reviewed the case, clarifying the standard for refiling charges after a dismissal for insufficient evidence. The court held that the State must show that it did not act in bad faith or with intent to harass when refiling charges. The court vacated the magistrate's ruling and remanded the case for further proceedings under the clarified standard. The court instructed the lower court to determine whether the State acted in bad faith when it failed to argue the enticement theory at the first preliminary hearing and subsequently refiled the charges. If the State prevails, it may proceed with a second preliminary hearing on both theories of nonconsent. If Labrum prevails, the State may only proceed on the lesser charges. View "State v. Labrum" on Justia Law

Several young Utah residents filed a lawsuit challenging statutory provisions and government actions related to fossil fuel development. They claimed that these provisions and actions were designed to maximize fossil fuel development in Utah, which they argued endangered their health and shortened their lifespans by exacerbating climate change. They sought a declaration from the district court that these provisions and actions violated their rights under the Utah Constitution.The government defendants moved to dismiss the case, arguing that the requested relief would not redress the alleged injuries. The Third District Court, Salt Lake County, agreed and dismissed the claims with prejudice, concluding that the plaintiffs lacked standing because their claims were not redressable.The Utah Supreme Court reviewed the case and affirmed the dismissal on the ground that the district court lacked subject-matter jurisdiction. The court found that the challenge to the energy policy provision was moot because the legislature had significantly amended the statute since the complaint was filed. The plaintiffs lacked standing to challenge the remaining statutory provisions because success on those challenges would not provide relief likely to redress their injuries. The court noted that the challenged provisions did not limit the government defendants' discretion in making decisions about fossil fuel development, and thus, striking these provisions would not necessarily lead to less fossil fuel development.The court also held that the challenges to the government defendants' conduct were not justiciable because they were not supported by a concrete set of facts. The plaintiffs had identified general categories of conduct without tying their claims to any specific government actions. The court instructed the district court to modify its ruling to reflect that the dismissal was without prejudice, allowing the plaintiffs the opportunity to refile their claims if they could address the jurisdictional deficiencies. View "Roussel v. State" on Justia Law

In 2016, Chad Hintze, a registered sex offender, visited a public park, violating his sex offender registry conditions. He was charged with a class A misdemeanor in 2018 while serving a prison sentence for a separate offense. However, the State did not notify Hintze of the charge until March 2020, when he was being considered for parole on the separate offense. The State began prosecuting the misdemeanor in June 2020 after Hintze requested a hearing.Hintze moved to dismiss the charge, claiming his Sixth Amendment right to a speedy trial was violated due to the State's two-year delay, which he argued prejudiced his parole chances. The Third District Court, Salt Lake County, disagreed, finding Hintze's prejudice claim speculative and determining that his speedy trial right was not violated based on the Barker v. Wingo framework. Hintze entered a conditional guilty plea and appealed.The Utah Court of Appeals, in a divided decision, reversed the district court's ruling, concluding that the Barker factors favored Hintze and required dismissal of the case on Sixth Amendment grounds. The State then petitioned the Utah Supreme Court for certiorari review.The Utah Supreme Court reviewed the case and concluded that although the two-year delay was significant, the Barker factors, when appropriately weighed, did not establish a violation of Hintze’s speedy trial right. The court found that the delay, caused by the State's negligence, was not extraordinary, and Hintze's claim of prejudice was speculative. Consequently, the court reversed the court of appeals' decision, reinstated Hintze’s conviction, and remanded the case to the court of appeals for further proceedings on Hintze’s motion to suppress. View "State v. Hintze" on Justia Law