Justia Utah Supreme Court Opinion Summaries

In April 2002, Ogden City Police Officer Troy Burnett and another officer searched Plaintiff's motel room and found drugs and a firearm. Plaintiff pled guilty to two federal offenses, but the court of appeals overturned Plaintiff's conviction, concluding that the search violated the Fourth Amendment. Plaintiff subsequently brought a claim under 42 U.S.C. 1983 against Burnett in federal court based on the unreasonable search. Under the Tenth Circuit Court of Appeals' decisions at the time Plaintiff filed his complaint, approximately two years remained in the limitations period before his claim would become time-barred. A U.S. Supreme Court decision four days after the filing, however, overturned the Tenth Circuit's decisions and rendered Plaintiff's complaint approximately ten months late. The district court granted summary judgment to Burnett, concluding that, as a result of the U.S. Supreme Court's decision, Plaintiff's claim was time-barred and Plaintiff was not entitled to equitable tolling. The Tenth Circuit Court of Appeals subsequently certified a question to the Utah Supreme Court, which answered by holding that under Utah law, an intervening change in controlling law that extinguishes a previously timely cause of action does merit equitable tolling of the statute of limitations. View "Garza v. Burnett" on Justia Law

In 1993, Jed Gressman was convicted of aggravated sexual assault and sentenced to a term of five years to life. In 1996, Gressman moved to dismiss the charges against him based on newly-discovered evidence. The district court vacated Gressman's conviction based on the newly-discovered evidence. In 2009, Gressman filed suit under the Post-Conviction Remedies Act (PCRA) seeking to obtain his factual innocence and obtain financial assistance. Gressman died during pendency of the suit, so counsel moved to substitute Gressman's widow. The district court substituted Gressman's widow, granted Gressman's widow's motion for summary judgment, and awarded Gressman's widow PCRA assistance payments, including prejudgment interest. The State appealed. The Supreme Court reversed for further proceedings, holding (1) Gressman's PCRA claims survived his death, and thus, the district court properly substituted Gressman's widow as the plaintiff in this suit; (2) the district court erred when it found that the vacatur of Gressman's conviction conclusively established his factual innocence as defined by the PCRA; and (3) the district court erred in awarding prejudgment interest. View "Gressman v. State" on Justia Law

Defendant was convicted of aggravated assault for stabbing the victim. At trial, the district court instructed the jury on self-defense. However, the court refused to instruct the jury on defense of a third person because it determined that Defendant's theory that he stabbed the victim in defense of a third person was not supported by the evidence. The court of appeals affirmed, concluding that a jury could not reasonably have concluded that the third person was in imminent danger at the time of the assault. The Supreme Court affirmed, holding that there was no basis in the evidence to support Defendant's theory that he acted in defense of the third person when he stabbed the victim.View "State v. Berriel" on Justia Law

Defendant pled guilty to possession of a controlled substance in a drug free zone and was sentenced to a term of incarceration for five years to life. Defendant appealed, arguing that the district court erred in denying his motion to suppress evidence obtained through a search of his vehicle. Specifically, Defendant argued that the search was unlawful because, among other reasons, the officers did not have reasonable suspicion that there were drugs in his vehicle when they stopped him for a traffic infraction. The Supreme Court reversed, holding that the district court erred when it denied Defendant's motion to suppress the evidence, as the officers, who had possessed reasonable suspicion that Defendant was engaged in or about to be engaged in criminal activity, improperly extended the original purpose of the stop, which was to investigate a minor traffic infraction, and instead undertook a prolonged investigation into Defendant's possible drug activity. Remanded. View "State v. Gurule" on Justia Law

Appellants were a group of current and former legislators, other elected and unelected government officials, and citizens. Appellants filed suit against the State's attorney general, treasurer, and the executive director of the Department of Human Resources (collectively, Appellees), seeking a declaration that Senate Bill 2, a bill related to education, was unconstitutional and an injunction against its implementation. Appellants claimed the Bill was unconstitutional in four respects. The first two claims fell under Utah Const. art. VI, 22, and the second two claims fell under Utah Const. art. X, 3. The district court dismissed the Article VI claims for failure to state a claim, and later granted Appellees' motion for summary judgment on the Article X claims. At issue on appeal was whether Appellants had standing to bring these claims in the first place. The Supreme Court held (1) Appellants had public-interest standing to bring the Article VI claims, but the district court properly dismissed the claims under Utah R. Civ. P. 12(b)(6); and (2) Appellants did not have standing to bring the Article X claims, and therefore, summary judgment on these claims, rather than dismissal, was improper.View "Gregory v. Shurtleff" on Justia Law

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