Justia Utah Supreme Court Opinion Summaries

Plaintiff filed a public records request under the Government Records Access and Management Act (GRAMA) seeking bank records the State had legally seized during a criminal investigation. The district court denied the request, concluding that article I, section 14 of the Utah Constitution provides a broad right of privacy that prevented the State from disclosing the records. The district court also denied Plaintiff access to a summary of the bank records (the Quicken Summary) and an investigator’s handwritten notes (the Post-it Note), concluding that both documents were protected attorney work product. The Supreme Court reversed, holding (1) there can be no violation of section 14 when the government obtains information through a valid warrant or subpoena, and therefore, the bank records were not exempted from GRAMA’s public disclosure requirements; and (2) the district court correctly classified the Quicken Summary and the Post-it Note as attorney work product, but, because the State terminated its investigation years ago, the interests favoring protection were not as compelling as those favoring disclosure. View "Schroeder v. Utah Attorney General’s Office" on Justia Law

The State sought and received an order freezing more than $3 million of Frank and Joan Steed’s assets under Utah’s Asset Preservation Statute. The State subsequently filed criminal charges against the Steeds and sought a freeze order to ensure adequate funds would be available for the anticipated restitution award. The district court upheld the freeze order. Thereafter, the Steeds were convicted of three counts of failure to file tax returns and one pattern count of criminal fraud. The Steeds later filed a motion challenging the constitutionality of the Asset Preservation Statute, both facially and as applied. The district court denied the motion. Joan subsequently conceded the issue of technical mootness but argued that the mootness exception applied. The Supreme Court dismissed the case, holding that this case was moot and that Joan’s claims did not warrant the application of the mootness exception. View "State v. Steed" on Justia Law

Jake Strickland was involved in a sexual relationship with W.P. while W.P. was married to someone else. When W.P. became pregnant, W.P. informed Strickland that he was the father. W.P. represented to Strickland that she would not place B.Y. up for adoption, but the day after B.Y. was born, W.P. relinquished her parental rights and placed the child for adoption. When Strickland learned of W.P.’s actions, he promptly commenced a paternity action and then moved to intervene in the pending adoption proceeding. The district court ruled that Strickland had no interest in the adoption proceeding because he failed strictly to comply with the statutory requirements for contesting B.Y.’s adoption and that “fraudulent representation” is not an excuse for failing to strictly comply with the Adoption Act. The court also rejected Strickland’s constitutional challenges to the Adoption Act. The Supreme Court affirmed, holding that Strickland had no viable interest in the child in question because he forfeited his parental rights as a result of a private bargain he struck with W.P., not because of any unconstitutional or otherwise unlawful state action. View "In re B.Y." on Justia Law

Utah County established an off-site work-release program for potentially dangerous inmates in its custody and screened each inmate before placing them with employers. Shawn Michael Leonard escaped while on the work-release program and assaulted Plaintiff near the Provo River Trail. Plaintiff survived, but her injuries were substantial. Plaintiff filed a negligence action against the County. The district court ruled in favor of the County, concluding that it did not owe a duty to Plaintiff and, alternatively, that the Utah Governmental Immunity Act barred all of Plaintiff’s claims. The Supreme Court affirmed the district court’s decision dismissing Plaintiff’s negligence claims against the County, holding (1) the County owed Plaintiff a duty of care because it took affirmative steps that created a risk of harm; but (2) the Governmental Immunity Act is not unconstitutional as applied in this case, where work-release programs are essential to the core governmental activity of housing and rehabilitating inmates, and therefore, governmental immunity barred Plaintiff’s claim. View "Scott v. Universal Indus. Sales" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated murder and one count of theft by receiving a stolen motor vehicle. Defendant was sentenced to life in prison without the possibility of parole on the aggravated murder counts. Defendant appealed, raising several claims of ineffective assistance of counsel. The Supreme Court granted Defendant’s motion for remand and stayed the appeal. After a hearing, the district court rejected all of Defendant’s claims. The Supreme Court affirmed Defendant’s convictions, holding that defense counsel either did not perform deficiently or that Defendant failed to show prejudice stemming from defense counsel’s alleged deficiencies. View "State v. Nelson" on Justia Law

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