Justia Utah Supreme Court Opinion Summaries

In 1985, Douglas Carter was convicted and sentenced to death for the murder of Eva Olesen in Provo, Utah. There was no physical evidence linking Carter to the crime scene, but he signed a confession, and two witnesses, Epifanio and Lucia Tovar, provided testimony corroborating aspects of his confession. Decades later, the Tovars signed declarations stating that the police had threatened them, pressured them to make untrue statements, and instructed them to lie at Carter’s trial about financial support they had received from the police. Based on these revelations, Carter petitioned for postconviction relief.The Fourth Judicial District Court held an evidentiary hearing and found that Carter’s trial and sentencing were tainted by serious misconduct by the lead prosecutor, the lead investigator, and another police officer. The court found that the police had suborned perjury, threatened the Tovars with deportation and separation from their son, and provided them with financial assistance, which they were instructed to lie about. The prosecutor did not disclose this information to the defense or correct the false testimony at trial.The Utah Supreme Court reviewed the case and agreed with the lower court’s findings. The court concluded that the State had violated Carter’s constitutional right to due process by suppressing evidence favorable to Carter and by failing to correct false testimony. The court determined that these violations prejudiced Carter at both the guilt and sentencing stages of his trial. The court affirmed the lower court’s decision to grant Carter’s petition for postconviction relief, vacate his conviction and sentence, and order a new trial. View "Carter v. State" on Justia Law

Kyli Jenae Labrum was charged with ten counts of rape and one count of forcible sexual abuse after allegedly engaging in a sexual relationship with T.S., a sixteen-year-old boy. The State's case relied on two theories of nonconsent: a special trust theory and an enticement theory. At the preliminary hearing, the stand-in prosecutor only argued the special trust theory, which the magistrate judge rejected, ruling that the State had not shown the relationship was nonconsensual. The State then moved to reduce the charges to a lesser offense but later decided to pursue the original charges, filing a motion for reconsideration and then refiling the charges with both theories of nonconsent.The magistrate judge denied the motion for reconsideration and dismissed the refiled charges, ruling that the State's actions were procedurally inappropriate and constitutionally barred under the Utah Constitution’s Due Process Clause. The State appealed, arguing that the magistrate erred in its determination.The Utah Supreme Court reviewed the case, clarifying the standard for refiling charges after a dismissal for insufficient evidence. The court held that the State must show that it did not act in bad faith or with intent to harass when refiling charges. The court vacated the magistrate's ruling and remanded the case for further proceedings under the clarified standard. The court instructed the lower court to determine whether the State acted in bad faith when it failed to argue the enticement theory at the first preliminary hearing and subsequently refiled the charges. If the State prevails, it may proceed with a second preliminary hearing on both theories of nonconsent. If Labrum prevails, the State may only proceed on the lesser charges. View "State v. Labrum" on Justia Law

The State of Utah charged Kouri Darden Richins with aggravated murder and other crimes. The case received significant media attention, with extensive coverage from various media outlets. The State and Richins jointly requested that jury selection be held in person and that the jury venire be expanded to include prospective jurors from both Summit and Salt Lake counties. The Third District Court has a standing order requiring virtual jury selection unless "extraordinary circumstances" are found. The Presiding Judge denied the request for in-person jury selection, stating that media attention did not constitute extraordinary circumstances. The Trial Judge initially granted the request to expand the jury venire but later reversed his decision.The Third District Court's Presiding Judge denied the request for in-person jury selection, concluding that the intense media attention did not constitute extraordinary circumstances. The Trial Judge initially approved the request to expand the jury venire but reversed his decision after the Presiding Judge's order, concluding that Utah law did not permit summoning jurors from multiple counties for one trial.The Supreme Court of the State of Utah reviewed the case. The court held that the Presiding Judge did not abuse her discretion in denying the request for in-person jury selection, as the decision was within the bounds of reasonability. The court also held that the Trial Judge correctly interpreted Utah law, which requires jurors to be selected from a single county. The court affirmed the decisions of both the Presiding Judge and the Trial Judge, concluding that the requests for in-person jury selection and an expanded jury venire were properly denied. View "State v. Richins" on Justia Law

Seth Clark Jolley was charged with raping T.T. Before his trial, Jolley moved under rule 412 of the Utah Rules of Evidence to determine the admissibility of evidence that he and T.T. had previously engaged in other sexual conduct. Rule 412 generally prohibits the admissibility of a victim’s other sexual behavior but allows exceptions under certain circumstances, such as to prove consent. Jolley filed a motion describing the evidence he sought to admit, stating that either he or T.T. would be its source.The Fourth District Court in Juab County concluded that Jolley had met his burden under rule 412 and that the incidents he wanted to inquire about were proper questions for an in camera hearing. T.T. objected, arguing that Jolley could not use rule 412 to compel her to testify about her alleged sexual behavior at the hearing. The court disagreed and ordered T.T. to testify, reasoning that the purpose of the 412 hearing was to identify the evidence for presentation to a jury.The Supreme Court of the State of Utah reviewed the case and concluded that the district court erred in its interpretation of rule 412. The court held that a party seeking to admit evidence under a rule 412(b) exception cannot compel a victim to testify at a rule 412 hearing. The court emphasized that the purpose of the rule 412 hearing is to give the victim and parties a right to attend and be heard, not to compel the victim to provide testimony. Accordingly, the Supreme Court reversed the district court’s denial of T.T.’s motion to quash Jolley’s subpoena and remanded for further proceedings. View "State v. Jolley" on Justia Law

In 2016, Monte Cooke was involved in a traffic accident that resulted in one death and serious injury to another person. Cooke was charged with two second-degree felony counts for negligently driving with a measurable amount of a controlled substance in his body, causing death or serious bodily injury. Before his trial, the Utah Legislature repealed and replaced the statute under which Cooke was charged.Cooke filed a motion to dismiss the charges, arguing that he could not be prosecuted under a repealed statute. The Fourth District Court in Provo denied his motion, ruling that Utah’s general saving statute, Utah Code section 68-3-5, protects criminal prosecutions initiated before a statute’s repeal. The Utah Court of Appeals granted Cooke’s petition to appeal the interlocutory order and certified the matter to the Utah Supreme Court.The Utah Supreme Court held that Utah’s general saving statute allows a prosecution to proceed unabated when the statutory basis for the charge is repealed before trial. The court concluded that the plain language of the saving statute indicates that a statute’s repeal does not affect actions already commenced under that statute, including criminal actions. The court also determined that its decisions in Belt v. Turner and its progeny, which require the application of ameliorative sentencing amendments before sentencing, do not preclude this result. Therefore, the court affirmed the district court’s decision to proceed with Cooke’s trial under the repealed statute and remanded the case for further proceedings. View "State v. Cooke" on Justia Law

In 2001, Morris Mullins, then seventeen, killed a seventy-eight-year-old widow, Amy Davis, in her home. He was charged as an adult with rape and aggravated murder. Mullins pled guilty to aggravated murder in exchange for the State dropping the rape charge and not seeking the death penalty. He was sentenced to life without parole (LWOP). At sentencing, the court considered evidence of Mullins's dysfunctional upbringing and psychological evaluations but ultimately imposed a juvenile life without parole (JLWOP) sentence.Mullins later challenged his sentence as unconstitutional, citing the Eighth Amendment and the Utah Constitution. In 2013, he filed a pro se motion to correct an illegal sentence under rule 22(e) of the Utah Rules of Criminal Procedure, arguing that his sentence was unconstitutional under Miller v. Alabama, which held that mandatory JLWOP for juveniles violated the Eighth Amendment. The district court denied his motion in 2016, and Mullins's appeal was delayed until 2020 due to ineffective assistance of counsel.The Utah Supreme Court reviewed the case, focusing on whether Mullins's JLWOP sentence was constitutional. The court held that the sentencing judge's comments suggested ambiguity about Mullins's capacity for change, which undermined confidence in the appropriateness of the JLWOP sentence. The court vacated Mullins's sentence and remanded for resentencing, emphasizing the need to consider Mullins's youth and potential for rehabilitation in light of Miller and its progeny. The court did not find the sentencing statute unconstitutionally vague or the JLWOP categorically unconstitutional but required a more thorough consideration of Mullins's youth and potential for change. View "State v. Mullins" on Justia Law

Deon Jennings was arrested and charged with first-degree murder after stabbing Willie Houston twice in the back, resulting in Houston's death. Jennings argued at a bail hearing that he should be released on bail because the State had not presented substantial evidence to support the charge, claiming he did not intend to injure Houston and acted in self-defense. The district court rejected Jennings' arguments and ordered him held without bail. Jennings appealed, and the Utah Court of Appeals affirmed the district court's decision.The Utah Court of Appeals reviewed the case and concluded that the State had presented substantial evidence of the requisite mens rea for first-degree murder. The court noted that Jennings' own statements and the nature of Houston's injuries provided a reasonable basis for a jury to conclude that Jennings intended to cause serious bodily injury to Houston. The court also addressed the issue of self-defense, assuming for the sake of argument that the State had the burden to disprove self-defense at the bail hearing. The court found that the State had met this burden, as Jennings' statements indicated he did not feel threatened by Houston, and the evidence suggested that any belief Jennings might have had that Houston posed an imminent threat was not reasonable.The Utah Supreme Court reviewed the case and affirmed the court of appeals' decision. The Supreme Court held that the State presented substantial evidence of Jennings' intent to cause serious bodily injury to Houston, as required for a first-degree murder charge. The court also agreed that the State had presented substantial evidence disproving Jennings' claim of self-defense, noting that Jennings' own statements and the circumstances of the altercation did not support a reasonable belief that he was acting in self-defense. View "State v. Jennings" on Justia Law

Stephen Rippey pled guilty to one count of aggravated sexual abuse of a child and one count of object rape of a child. He was sentenced to two concurrent prison terms of fifteen years to life. Ten years after his conviction, a district court reinstated Rippey’s time to file a direct appeal. On appeal, Rippey challenged several aspects of his plea, conviction, and sentence, leading the Supreme Court of Utah to address whether the Plea Withdrawal Statute (PWS) is constitutional.The Third District Court in West Jordan initially accepted Rippey’s guilty plea after a colloquy and a signed plea form. Rippey did not move to withdraw his plea before sentencing. He later filed a pro se petition for post-conviction relief under the Post-Conviction Remedies Act (PCRA), listing seventeen claims. The district court dismissed eight claims as frivolous and the remaining claims for failure to state a claim. Rippey’s requests for appointed counsel were denied. The Utah Court of Appeals upheld the district court’s dismissal, concluding that Rippey’s claims were unpreserved except for ineffective assistance of counsel, which lacked merit.The Supreme Court of Utah reviewed the constitutionality of the PWS, specifically subsections (2)(b) and (2)(c). The court held that subsection (2)(b)’s preservation rule and the corresponding waiver in subsection (2)(c) violate the separation of powers under the Utah Constitution. These provisions were deemed procedural, not substantive, and thus beyond the legislature’s authority to enact. The court concluded that the PWS does not bar Rippey’s challenge to his guilty plea, and his appeal is now governed by standard rules of preservation. The court instructed the parties to brief the merits of Rippey’s challenges under these standards. View "State v. Rippey" on Justia Law

The case involves William Torres, who was convicted by a jury of one count of rape. The district court had concerns about the performance of Torres's trial counsel and appointed post-trial counsel to investigate potential errors. Torres, through his new counsel, moved for a new trial, arguing ineffective assistance of counsel under the Strickland v. Washington standard, which requires showing that counsel's performance was deficient and that the deficient performance prejudiced the defense.The district court granted Torres a new trial, finding that his trial counsel's performance was objectively unreasonable in several respects and that these errors cumulatively prejudiced Torres. The court concluded that Torres received ineffective assistance of counsel and ordered a new trial under rule 24(a) of the Utah Rules of Criminal Procedure.The State appealed, and the Utah Court of Appeals reversed the district court's decision. The court of appeals reviewed the district court's determination of ineffective assistance of counsel for correctness, as per existing precedent. The court concluded that Torres had failed to show that his trial counsel's performance was both deficient and prejudicial under Strickland.On certiorari, Torres argued that the court of appeals applied the wrong standard of review and that the district court's ruling should be reviewed for abuse of discretion. The Utah Supreme Court rejected this argument, affirming that legal decisions embedded in a district court's new trial ruling are reviewed for correctness. The court also declined to overrule its precedent in Menzies v. Galetka, which holds that ineffective assistance is a law-like mixed question reviewed for correctness.The Utah Supreme Court agreed with the court of appeals that Torres had not established a reasonable probability of a different result at trial absent counsel's alleged errors. Consequently, the court affirmed the decision of the court of appeals, reversing the district court's grant of a new trial and remanding for sentencing. View "State v. Torres-Orellana" on Justia Law

In 2015, Michael Jerry Felts pled guilty to assaulting a police officer and failing to stop at the command of police. The State sought restitution for damage to a police vehicle during the pursuit. The district court referred the restitution question to the Board of Pardons and Parole, which ordered Felts to pay $9,415.28 in June 2021. Felts objected, arguing that insurance had already covered the damage. After legislative amendments in July 2021 removed the Board's authority to issue restitution orders and allowed for judicial review of such orders, Felts contended that the district court could now review the Board's order.The district court held that it lacked jurisdiction to review the Board's restitution order. The Utah Court of Appeals affirmed, stating that the legislative amendments did not retroactively grant district courts the authority to review Board-issued restitution orders. The court of appeals concluded that the amendments were intended to clarify and consolidate restitution authority in district courts moving forward, not to provide retroactive judicial review of past Board decisions.The Utah Supreme Court reviewed the case and affirmed the court of appeals' decision. The Supreme Court held that the legislative amendments did not grant district courts the authority to review restitution orders issued by the Board of Pardons and Parole. The court emphasized that the plain language of the amendments did not support Felts's interpretation and that the removal of the prohibition on judicial review of Board restitution orders was for clarity and consistency, not an independent grant of judicial review. The court also noted that Felts could seek relief through an extraordinary writ under rule 65B of the Utah Rules of Civil Procedure, but he had not pursued that option. View "State v. Felts" on Justia Law