Justia Utah Supreme Court Opinion Summaries

Defendant was working as an aide at a middle school when she was convicted of rape, forcible sodomy, and forcible sexual abuse for incidents involving a fifteen-year-old student student and his friend. The trial judge arrested the judgment and granted a new trial on all counts based on evidentiary errors and several irregularities that occurred during trial. The State appealed. The Supreme Court reversed the order granting a new trial and reinstated Defendant's convictions, holding (1) the evidentiary ruling excluding evidence of the victim's sexual predisposition was proper; and (2) the other claimed errors and irregularities did not require reversal because they did not prejudice Defendant.View "State v. Billingsley" on Justia Law

In 2006, the Central Utah Water Conservancy District (District) filed an action to condemn six waterfront lots owned by Petitioner. When negotiations reached an impasse on the value of the lots, the District instituted the underlying condemnation proceeding. The jury returned a verdict for Petitioner in the amount of $56,000. Petitioner filed a motion for a new trial, which the district court denied. Petitioner filed an appeal less than thirty days after the entry of the district court's ruling and order. The court of appeals dismissed Petitioner's appeal without prejudice based upon lack of jurisdiction, holding that under Utah R. Civ. P. 7(f)(2) and the Supreme Court's decision in Giusti v. Sterling Wentworth Corp., Petitioner's appeal was not ripe because it was not taken from a final, appealable order. The Supreme Court affirmed, holding that under Rule 7(f)(2), Petitioner's appeal was premature and that the court of appeals therefore correctly dismissed it without prejudice.View "Central Utah Water Conservancy Dist. v. King" on Justia Law

Defendant confessed to shooting a female victim during a custodial interrogation by detectives. Defendant moved to suppress the confession on the grounds that it was coerced. The district court granted the motion based on the detectives' invocation of Defendant's children as a method to get a confession. After clarifying that a confession is involuntary if the will of the accused has been overcome, the Supreme Court reversed, holding that, under the totality of the circumstances of this case, Defendant's free will was not overcome, and therefore, the district court erred in concluding that the references in the interrogations to Defendant's children were coercive police tactics that rendered Defendant's confession involuntary. Remanded. View "State v. Arriaga-Luna" on Justia Law

Defendant pled guilty to aggravated murder and aggravated assault. Defendant subsequently filed a motion to withdraw his plea, stating that he was confused when he entered his plea. The district court denied the motion, concluding that Defendant was adequately informed of the nature of the charge and was not confused. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) Defendant received constitutionally adequate notice of the nature of the charge of his limited appeal rights; and (2) the district court did not abuse its discretion in determining that Defendant entered his plea knowingly and voluntarily. View "State v. Candland" on Justia Law

Officer Dennis Nelson, a police officer with the Orem City Police Department (OCPD), was terminated from his position for using excessive force during a booking at the Orem City Jail. The Orem City Employee Appeals Board (Board) upheld the termination. The court of appeals upheld the Board's decision, concluding (1) the OCPD's decision to terminate Nelson was not inconsistent with prior instances of discipline under OCPD's excessive force policy; (2) alternatively, the Board justified any disparate application of OCPD's policy; and (3) the Board did not violate Nelson's procedural due process rights at his hearing before the Board. The Supreme Court affirmed, holding (1) the court of appeals did not err in applying an abuse of discretion standard of review; and (2) the court of appeals correctly found that any procedural due process violations at the hearing were harmless. View "Nelson v. City of Orem" on Justia Law

The City police department fired a police officer (Plaintiff) for reporting for duty while under the influence of alcohol. The board of appeals and court of appeals affirmed the decision. The Supreme Court affirmed, holding (1) substantial evidence supported the conclusion that Plaintiff was under the influence of alcohol, in violation of the City's alcohol policy, as the portable breath test administered to Plaintiff accurately measured Plaintiff's breath alcohol and blood alcohol content; and (2) Utah Code 34-38-7 does not prohibit the City from deviating from its specified procedure of testing urine to establish blood alcohol content, as the statute does not apply to the City. View "Becker v. Sunset City" on Justia Law

After a trial, Defendant was convicted of vaginal rape and forcible anal sodomy. Defendant appealed, arguing that the trial court's exclusion prior instances of sexual conduct between Defendant and the victim under Utah R. Evid. 412(b)(2)(A) was error. Specifically, Defendant unsuccessfully sought to offer evidence that he and the victim had previously engaged in consensual oral and anal sex through his own testimony and the testimony of witnesses. The Supreme Court reversed, holding that the trial court's exclusion of Defendant's proffered sexual history evidence under Rule 412(b)(2)(A) was error that undermined the jury's verdict. Remanded for a new trial. View "State v. Richardson" on Justia Law

Federal National Mortgage Association (FNMA) initiated an unlawful detainer action against Appellant, claiming ownership of Appellant's home pursuant to a trustee's deed it obtained from ReconTrust, a national bank that conducted a nonjudicial foreclosure sale in its capacity as trustee of the trust deed that Appellant had executed to secure her mortgage. After an immediate occupancy hearing, the district court entered an order of restitution requiring that Appellant vacate her home. At issue on appeal was whether ReconTrust had authority to conduct the foreclosure sale and convey Appellant's home to the FNMA where Utah Code 57-1-21 and 57-1-23 limits the power of sale to trustees who are either members of the Utah State Bar or title insurance companies with an office in Utah. The district court concluded that ReconTrust, as a national bank, was authorized to conduct the sale under federal law and that federal law preempted Utah law. The Supreme Court vacated the district court's order of restitution, holding that the relevant Utah statutes were not preempted by federal law, and therefore, a national bank seeking to foreclose real property in Utah must comply with Utah law. Remanded. View "Fed. Nat'l Mortgage Ass'n v. Sundquist" on Justia Law

Defendant, a New Mexico resident, was arrested in Utah and indicted on federal charges of coercion and enticement of a fifteen-year-old. Defendant was returned to New Mexico to await trial and remained there for more than two years, returning to Utah on a few occasions to attend proceedings in federal court. The federal charges were subsequently dismissed. Thereafter, the State of Utah charged Defendant with enticement of a minor. Defendant moved to dismiss the charge as untimely under the applicable statute of limitations. The district court denied Defendant's motion. At issue on appeal was the applicability of the criminal tolling statute, which tolls the limitations period while a defendant is out of the state. The Supreme Court affirmed, holding that the criminal tolling statute applied to Defendant even though he was present in Utah during the course of the federal court proceedings, as (1) Defendant was only loosely subject to the authority of the State during the federal proceedings against him; and (2) applying the statute to Defendant did not violate the Uniform Operation of Laws provision of the Utah Constitution. View "State v. Canton" on Justia Law

Plaintiffs were camping with their young son, Sam, when a bear pulled Sam from out of his tent and killed him. The bear was the same bear that had attacked another camper in the same campsite earlier that day. Plaintiffs sued the State, alleging that the State negligently failed to warn them of the dangerous condition created by the bear. The district court initially dismissed Plaintiffs' claims under the permit exception to the Utah Governmental Immunity Act. The Supreme Court reversed. On remand, the State filed a motion for summary judgment, raising two alternative arguments that the Supreme Court declined to address in Francis I. The district court subsequently granted summary judgment for the State on both duty and immunity grounds. The Supreme Court reversed, holding (1) the State was entitled to present its alternative arguments on remand; (2) the State owed Plaintiffs a duty because it undertook no specific action to protect them as the next group to use the campsite; and (3) the natural condition exception to the Immunity Act did not immunize the State from liability because a bear is not a "natural condition on publicly owned or controlled lands." View "Francis v. State" on Justia Law