Justia Utah Supreme Court Opinion Summaries

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

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