Justia Utah Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder. Fourteen years later, Defendant filed a petition for a post-conviction determination of factual innocence pursuant to Utah's Post-Conviction Remedies Act (PCRA). After an evidentiary hearing, the post-conviction court vacated Defendant's murder conviction, determining (1) the PCRA allows a determination of factual innocence to be based on a combination of newly discovered evidence and previously available evidence; and (2) Defendant established her factual innocence by clear and convincing evidence. The Supreme Court affirmed, holding (1) a post-conviction determination of factual innocence can be based on both newly discovered evidence and previously available evidence; and (2) the State did not properly challenge the post-conviction court's factual findings, and therefore, the post-conviction court's ultimate determination that Defendant was factually innocent was affirmed. View "Brown v. State" on Justia Law

Appellants were defrauded by an individual on parole from a Utah prison. Appellants filed a complaint alleging causes of action against the State for negligent supervision, gross negligence, failure to warn, and negligent misrepresentation. Under the Governmental Immunity Act, the State is immune from a suit where the injury arises out of deceit. The district court dismissed the case based on the State's governmental immunity, finding that Appellants' injury was the result of a third-party's deceit. The Supreme Court affirmed, holding (1) the State was immune under the Utah Governmental Immunity Act's deceit exception; and (2) the dismissal of Appellants' complaint on the basis of governmental immunity was timely. View "Van De Grift v. State" on Justia Law

At issue in this case were two agreements: a ground lease agreement between ASC Utah, Inc. (ASCU) and Wolf Mountain Resorts, and a specifically planned area (SPA) development agreement, which had thirty-six signatories, including ASCU, Wolf Mountain, the D.A. Osguthorpe Family Partnership (Osguthorpe). ASCU and Wolf Mountain began litigating claims involving both the ground lease and the SPA agreement. Shortly thereafter, Osguthorpe sued ASCU and Wolf Mountain, alleging that each party had breached a land-lease agreement distinct from the ground lease or the SPA agreement. The district court consolidated Osguthorpe's separate actions into ASCU's litigation. Osguthorpe later moved to compel arbitration on all the claims related to the SPA agreement, including the claims between ASCU and Wolf Mountain, to which Osguthrope was not a party. The district court denied Osguthrope's motion. Osguthrope withdrew its SPA claims from the case, leaving for appeal only Osguthrope's motion to compel arbitration of the SPA claims between ASCU and Wolf Mountain. The Supreme Court affirmed, holding (1) the disputes for which Osguthrope sought to compel arbitration were not subject to the SPA agreement's arbitration provision; and (2) furthermore, as a non-party to the disputes, Osguthrope had no contractual right to compel their arbitration. View "Osguthorpe v. Wolf Mountain Resorts, L.C." on Justia Law

Defendant pled guilty to disorderly conduct in the justice county and was sentenced to ninety days in jail and ordered to pay a fine. After conducting a trial de novo, the district court convicted Defendant of the original charge, sentenced him to 180 days in jail, and imposed a higher fine. Defendant petitioned the court of appeals for extraordinary relief, arguing that the district court violated Utah Code 76-3-405 when it imposed a more severe punishment than the one originally imposed by the justice court. The court of appeals denied the requested relief, reasoning that although the statute generally prohibits the imposition of a greater sentence after a defendant appeals, Defendant's case fell outside of the general rule because his original conviction and sentence resulted from a plea agreement. The Supreme Court affirmed, holding that the section 76-3-405(2)(b) exception against imposing a harsher sentence on appeal when a defendant has entered into a plea agreement applies to justice court proceedings. View "Vorher v. Court of Appeals" on Justia Law

The Utah Highway Patrol performed a drug interdiction exercise on a rural stretch of the interstate. UHP chose to focus the bulk of its enforcement efforts on cars bearing out-of-state license plates. Defendant's California-plated vehicle was stopped during the exercise, and the traffic stop yielded evidence of illegal drugs. Defendant was charged with possession with intent to distribute. Defendant filed two suppression motions - one based on the Equal Protection Clause and right to travel and the other rooted in the Fourth Amendment. The district court denied both motions, and Defendant entered a conditional guilty plea. On appeal, the Supreme Court affirmed, holding (1) the traffic stop did not restrict Defendant's movement in a manner implicating his fundamental right to travel; (2) because there was a rational basis for UHP's selective enforcement of traffic laws - by choosing to stop vehicles licensed outside of Utah - Defendant's equal protection claim was meritless; and (3) to the extent the district court erred in failing to consider any evidence of relevance to the Fourth Amendment motion to suppress, it was harmless error. View "State v. Chettero" on Justia Law

Michael Howe, an employee of Peak Alarm Company, filed a complaint against the City and several of its employees, presenting ten federal and state claims, including false arrest and defamation. The district court granted summary judgment in favor of Defendants on these and other state claims on the ground that Howe failed to comply with the procedural requirements of the Utah Governmental Immunity Act (UGIA). The supreme Court reversed, holding that the claims were timely brought under the UGIA. On remand, Defendants again moved for summary judgment, arguing that the state defamation and false arrest claims were barred by the one-year statute of limitations. The district court denied the motion on the ground that the claims had been timely brought under the UGIA. The Supreme Court affirmed, holding that the UGIA comprehensively governs claims against governmental parties such that plaintiffs are not bound to observe the statute of limitations that would apply to claims against private parties. View "Peak Alarm v. Salt Lake City Corp." on Justia Law

Defendant, a passenger in a vehicle stopped for a traffic infraction, was arrested for possession of methamphetamine after being questioned and searched by a deputy sheriff. Defendant moved to suppress the fruits of the search. The district court denied the motion to suppress, and the court of appeals affirmed. Defendant appealed, arguing that the deputy improperly extended the length of the detention without reasonable suspicion that Defendant was engaged in criminal activity. The Supreme Court affirmed, holding (1) the deputy's questioning of Defendant, during which Defendant admitted to possession of illegal drugs, was proper based on the deputy's reasonable suspicion brought about by the driver's likely impairment and the presence of used drug paraphernalia in plain sight; and (2) the deputy did not improperly extend the duration of Defendant's detention because the deputy's single question to Defendant resulted in only a de minimis extension of the otherwise lawful detention. View "State v. Simons" on Justia Law

Defendant as convicted of aggravated murder and attempted aggravated murder. Defendant's conviction was affirmed on appeal, after which he filed a pro se petition seeking relief under the Post-Conviction Remedies act (PCRA) on the grounds that his trial counsel was ineffective for failing to raise a defense and that his appellate counsel was ineffective for failing to raise a claim of ineffective assistance of counsel on direct appeal. The court granted summary judgment for the State, concluding that Defendant's appellate counsel was not ineffective and that Defendant's ineffective assistance of trial counsel claim was procedurally barred. The Supreme Court reversed, holding (1) disputed issues of material fact precluded summary judgment on Defendant's claim that his appellate counsel was ineffective; and (2) because the Court could not determine whether appellate counsel was ineffective, it could not determine whether Defendant's claim regarding trial counsel was procedurally barred by the PRCA. Remanded for an evidentiary hearing. View "Ross v. State" on Justia Law

In 2003, the City of Salt Lake asked voters to approve Proposition No. 5, which proposed the issuance of bonds to finance construction of a regional sports, recreation, and education complex. Voters approved the bonds. In 2011, the City authorized issuance of the bonds with Resolution No. 5 and then filed a petition to validate the Proposition No. 5 bonds in district court. Appellants, the Jordan River Restoration Network and several citizens, appeared pro se to oppose the City's petition, challenging the bonds' validity on several statutory and constitutional grounds. The district court denied Appellants' claim and granted the City's validation petition. The Supreme Court affirmed the City's validation petition, holding (1) the district court conducted the validation proceedings in compliance with due process and the Validation Act; and (2) the district court correctly applied the Local Government Bonding Act. View "Salt Lake City Corp. v. Jordan River Restoration Network" on Justia Law

After a jury trial, Petitioner was convicted of four counts of sodomy on a child and one count of sexual abuse of a child. The convictions were affirmed on direct appeal. Approximately a dozen years later, Petitioner filed a petition for post-conviction relief. The district court dismissed the petition as procedurally barred under the Post-Conviction Remedies Act's one-year statute of limitations. Petitioner appealed, arguing that applying the one-year statute of limitations to his petition violated the Utah Constitution under the "egregious injustice" exception set forth in Gardner v. State. The Supreme Court (1) affirmed the district court's dismissal of all but one of the claims alleged in Petitioner's petition; but (2) vacated the district court's dismissal of Petitioner's claim for ineffective assistance of counsel during the plea bargaining process, as Defendant may have a newly-recognized claim under the recent U.S. Supreme Court decision, Lafler v. Cooper, which could extend the statute of limitations on his claim. Remanded. View "Winward v. State" on Justia Law