Justia Utah Supreme Court Opinion Summaries

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

In 2021, Derek Willden was charged with multiple counts of physical and sexual assault. During trial preparations, the State requested that Willden disclose certain information under Utah Rule of Criminal Procedure 16(b), specifically audio recordings of interviews conducted by Willden’s counsel with witnesses. Willden objected, claiming the recordings were protected as attorney work product and that compelled disclosure would violate both Rule 16(b)(4) and his constitutional rights. The district court disagreed and ordered Willden to turn over the recordings within thirty days. Willden then sought an interlocutory appeal, which the court of appeals granted, and the case was recalled for direct review.The district court, presided over by the Honorable Elizabeth A. Hruby-Mills of the Third District, Salt Lake County, initially ruled in favor of the State’s discovery motion. The court reasoned that the recordings could be redacted to exclude any attorney’s opinions, analysis, or strategy, thus not constituting protected work product. Willden was given thirty days to comply with the order. Before the deadline, Willden petitioned for an interlocutory appeal, which was granted by the court of appeals, and the case was subsequently recalled for direct review by the Utah Supreme Court.The Utah Supreme Court reviewed the case and focused on the interpretation of Rule 16(b) following its 2021 amendment. The court held that the recorded interviews were indeed attorney work product and thus protected from compelled disclosure under Rule 16(b)(4). The court emphasized that the amended rule explicitly protects attorney work product from disclosure, without distinguishing between "core" and "factual" work product. Consequently, the district court’s order was reversed, and the case was remanded for further proceedings. The court did not address Willden’s constitutional arguments, as the case was resolved based on the interpretation of Rule 16(b). View "State v. Willden" on Justia Law

In 2018, Brevan Bringhurst Baugh was charged with two counts of aggravated sexual abuse of a child. The prosecution presented evidence of three instances of alleged abuse, distinguished by location, while the charges were distinguished by date. During closing arguments, the prosecution told the jury they could use any two of the three instances to fulfill the elements of the charged counts. The jury convicted Baugh on one count and acquitted him on the other.Baugh appealed to the Utah Court of Appeals, arguing that the jury might not have unanimously agreed on which instance of abuse supported the conviction. He also claimed his counsel was ineffective for not requesting specific jury instructions on unanimity. The court of appeals agreed, finding that the jury instructions were ambiguous and could have led to a non-unanimous verdict. The court vacated Baugh’s conviction.The Utah Supreme Court reviewed the case on certiorari. The court affirmed the court of appeals' decision, holding that Baugh’s counsel performed deficiently by failing to request more specific unanimity instructions. The court noted that the risk of a non-unanimous verdict was significant due to the way the evidence and charges were presented. The court also found that there was a reasonable probability that the jury would not have convicted Baugh if proper unanimity instructions had been given. Therefore, the court concluded that Baugh’s counsel was ineffective, and the conviction was vacated. View "State v. Baugh" on Justia Law

In 2008, Michael W. Thompson was convicted by a jury of two counts of forcible sodomy. Thompson appealed, arguing that his counsel was constitutionally ineffective. The Utah Court of Appeals agreed, reversed his conviction, and remanded for a new trial. The State chose not to retry Thompson, and the district court dismissed the case with prejudice. Thompson was released after serving several years in prison.Thompson later petitioned for a factual innocence determination under the Post-Conviction Remedies Act (PCRA), asserting that newly discovered material evidence proved his innocence. The post-conviction court held a hearing and concluded that Thompson had clearly and convincingly established his factual innocence. The State appealed this determination, arguing that the court misinterpreted the factual innocence statute by considering more than just the newly discovered evidence.The Utah Supreme Court reviewed the case and agreed with the State. The court held that under the plain language of the factual innocence statute, a determination of factual innocence must be based on newly discovered evidence, not evidence that was available at trial. The court found that the newly discovered evidence presented by Thompson, which included expert testimony that impeached a trial witness's testimony, did not clearly and convincingly establish his factual innocence. Consequently, the Utah Supreme Court reversed the post-conviction court's determination of factual innocence. View "Thompson v. State" on Justia Law

Douglas Lovell was convicted in 2015 for the murder of Joyce Yost, a crime he committed in 1985. Lovell had previously pled guilty to the murder in 1993 and was sentenced to death, but his plea was later withdrawn, leading to a new trial. During the new trial, Lovell did not contest his guilt but argued for a lesser sentence, presenting evidence of his remorse and rehabilitation.In the lower courts, Lovell's 1993 guilty plea was vacated by the Utah Supreme Court in 2011 due to procedural errors. The case was remanded for a new trial, where Lovell was again convicted and sentenced to death. Lovell appealed, arguing that the district court improperly admitted his testimony from the 1993 proceedings and that his counsel was ineffective during the penalty phase.The Utah Supreme Court reviewed the case. The court assumed, without deciding, that the district court erred in admitting Lovell's 1993 testimony but found the error harmless beyond a reasonable doubt due to the overwhelming evidence of Lovell's guilt. However, the court agreed with Lovell that his counsel was ineffective during the penalty phase. The court found that counsel failed to adequately object to prejudicial testimony regarding Lovell's excommunication from the Church of Jesus Christ of Latter-day Saints and the Church's doctrine on repentance and remorse. This testimony improperly suggested that the jury could rely on the Church's assessment of Lovell's remorse rather than making their own determination.The Utah Supreme Court held that this ineffective assistance of counsel prejudiced Lovell's ability to have a fair sentencing hearing. As a result, the court vacated Lovell's death sentence and remanded the case for a new sentencing proceeding. View "State v. Lovell" on Justia Law

The case involves Shane Craig Smith, who was arrested in a police sting operation after he attempted to engage in sexual activities with a persona named "Emily," who he believed to be a 13-year-old girl. Smith had met Emily online and had arranged to meet her at a gas station in Lehi, Utah, with the intention of having her perform multiple sex acts in exchange for driving her to California. Smith was charged with various crimes, including attempted child kidnapping, attempted rape of a child, and attempted sodomy of a child. He pled guilty to most of these charges while reserving the right to appeal two issues: whether there was sufficient evidence to bind him over for trial on the attempt charges, and whether he was entrapped as a matter of law.Smith's case was first heard in the district court, where he moved to decline to bind over the counts of attempted rape of a child, attempted sodomy of a child, and attempted kidnapping of a child. He argued that the State’s evidence regarding the attempt crimes did not show that his actions rose beyond solicitation or mere preparation and was therefore insufficient to support probable cause on the “substantial step” element of the attempt statute. The district court denied the motion and bound over all counts for trial. Smith then filed a motion to dismiss all charges on entrapment grounds, which the district court denied. Smith eventually entered a conditional guilty plea to attempted child kidnapping, attempted sodomy of a child, and enticement of a minor, allowing him to appeal the district court’s bindover ruling and entrapment determination.Smith appealed to the Utah Court of Appeals, where he raised two issues: whether there was insufficient evidence to bind over the attempt charges for trial, and whether the district court erred by denying his motion to dismiss all the charges on the basis that he had been entrapped. The court of appeals affirmed the district court’s rulings. Smith then petitioned for certiorari to the Supreme Court of the State of Utah.The Supreme Court of the State of Utah affirmed the decisions of the lower courts. The court found that Smith's actions constituted substantial steps toward the commission of the crimes he was charged with, and that he was not entrapped as a matter of law. The court held that Smith's actions strongly corroborated his intent to commit the crimes, and that the police conduct in the case did not create a substantial risk that an average person would attempt to commit the crimes that Smith attempted. View "State v. Smith" on Justia Law

The case involves the interpretation of Utah's Pretrial Justification Statute and its application to a situation where a defendant, Jon Michael Clara, claimed self-defense after firing his gun at a snowplow that had repeatedly rammed his vehicle. Clara was charged with seven counts of felony discharge of a firearm. He invoked the Pretrial Justification Statute, which allows a defendant to have a claim of self-defense assessed by a judge in a pretrial hearing. At the pretrial hearing, the defendant first has to make a prima facie claim of self-defense, then the prosecution must prove by clear and convincing evidence that the defendant’s use of force wasn't justified.At the pretrial hearing, Clara testified that after being rammed multiple times, he believed the snowplow was making a U-turn to attack again, leading him to fire his gun as a warning. The district court ruled that Clara had made a prima facie claim of self-defense and that the State had not disproved the self-defense claim by clear and convincing evidence. Therefore, the district court dismissed the charges against Clara.The State appealed, arguing that Clara failed to make a prima facie claim of self-defense, as the defendant’s belief in the imminence of the threat wasn’t objectively reasonable. The Supreme Court of the State of Utah, however, affirmed the district court’s ruling, stating that a reasonable person in Clara's position could have believed that the snowplow posed an imminent threat. View "State v. Clara" on Justia Law

In this appeal of a criminal case, the Supreme Court of the State of Utah concluded that the police officers' warrantless entry and search of Alexander Hung Tran’s home were reasonable and justified under the emergency aid exception to the Fourth Amendment of the United States Constitution. The court also declined to recognize broader protection under the Utah Constitution in the emergency aid context. The case arose when Tran appealed the district court’s denial of his motion to suppress evidence that police officers obtained during a warrantless entry and search of his home. The officers had entered Tran's home due to their belief that two individuals inside were in need of immediate aid, which was supported by a range of factors. The court held that the totality of the circumstances known to the police officers at the time they entered Tran’s home supported an objectively reasonable basis to believe that the two individuals were in need of immediate aid, thus falling within the emergency aid exception to the Fourth Amendment's warrant requirement. View "State v. Tran" on Justia Law