Justia Utah Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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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

Posted in: Criminal Law
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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

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In the case at hand, Robert Evan Woodham was convicted for failing to yield to stationary emergency vehicles in violation of Utah Code subsection 41-6a-904(2). The conviction was upheld by the district court, after which Woodham appealed to the Utah Court of Appeals. However, the appellate court dismissed his appeal for lack of jurisdiction, citing that the district court did not rule on the constitutionality of a statute or ordinance, which is a requirement for appellate review under Utah Code § 78A-7-118(11). Woodham then petitioned the Supreme Court of Utah, arguing the district court implicitly ruled on his constitutional argument.The Supreme Court of Utah clarified that an implicit ruling by the district court on the constitutionality of a statute or ordinance is sufficient to permit appellate review under Utah Code subsection 78A-7-118(11), overruling a contrary holding by the Utah Court of Appeals in Murray City v. Timmerman. However, the Court agreed with the appellate court's decision in Woodham's case, stating that he did not preserve a constitutional challenge to the emergency vehicle statute, and therefore, the district court did not implicitly rule on its constitutionality. Consequently, the dismissal of Woodham's appeal due to lack of jurisdiction was affirmed. View "Park City v. Woodham" on Justia Law

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In a case before the Supreme Court of the State of Utah, the petitioner, Elbert John Paule, was charged with murder, obstruction of justice, reckless endangerment, and assault following a fatal shooting incident involving a friend. The jury acquitted Paule on all charges except obstruction of justice. Paule challenged his conviction, arguing that the obstruction of justice conviction was legally inconsistent with the jury’s determination that he was not guilty of the other crimes. The Utah Court of Appeals affirmed the conviction. On certiorari review, the Supreme Court of the State of Utah affirmed the lower court's ruling.The Supreme Court held that to be convicted of obstruction of justice, a defendant need only perform an obstructive act with the requisite intent. Proof of a separate crime is not necessary. The court concluded that because a violation of Utah’s obstruction of justice statute requires only that a defendant act with the requisite intent—it does not require proof of a separate criminal offense—the jury’s verdict was not legally impossible. Furthermore, the court found that Paule's counsel was not constitutionally ineffective in failing to seek a more detailed unanimity instruction. View "State v. Paule" on Justia Law

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In the case before the Supreme Court of the State of Utah, the appellant, Troy Michael Kell, appealed the district court's dismissal of his second petition for post-conviction relief. Kell, while serving a life sentence for murder, had stabbed another inmate to death in 1994. He was convicted of aggravated murder, a capital offense, and sentenced to death. Following his conviction, Kell filed a petition for post-conviction relief which was dismissed by the district court.Years later, during federal habeas corpus proceedings, Kell's attorneys discovered evidence that three jurors from his trial had communicated with the judge during sentencing deliberations without Kell or either party’s counsel present. One of these jurors remembered the judge stating that it was Kell’s burden to convince the jury that his life should be spared. This new evidence formed the basis of Kell’s second petition for post-conviction relief which he filed in 2018, over five years after the evidence was discovered.The district court dismissed Kell's petition, applying the time and procedural limitations under the Post-Conviction Remedies Act (PCRA) and rule 65C of the Utah Rules of Civil Procedure. Kell argued on appeal that the district court erred in dismissing his petition based on these limitations. He claimed that his delay in filing was due to ineffective assistance of initial post-conviction counsel and that applying the PCRA’s time and procedural bars violated his rights under the Suspension Clause, Due Process Clause, and Open Courts Clause of the Utah Constitution.The Supreme Court of the State of Utah affirmed the district court's decision. The court held that Kell had not shown that any shortcoming of his initial post-conviction counsel excuses the five and a half year delay in bringing this claim after discovering the alleged improper communication between the trial judge and jurors. The court also held that Kell had not demonstrated that the application of the PCRA’s time and procedural bars to his claim violated his constitutional rights. He was unable to show that the application of these bars prevented him from challenging his detention or left him unable to vindicate his substantive rights. View "Kell v. Benzon" on Justia Law

Posted in: Criminal Law
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In the case before the Supreme Court of the State of Utah, the defendant, Alfonso Valdez, was arrested and charged with kidnapping and assaulting his ex-girlfriend. During the arrest, officers seized Valdez’s cell phone. The police later obtained a search warrant for the phone, but were unable to access the contents as they could not decipher Valdez's passcode. When asked to provide his passcode, Valdez refused. At trial, the State elicited testimony about Valdez's refusal to provide his passcode and argued that this refusal undermined one of his defenses. Valdez was subsequently convicted.On appeal, the court of appeals reversed the conviction, agreeing with Valdez that he had a Fifth Amendment right to refuse to provide his passcode, and that the State violated this right by using his refusal against him at trial.The State petitioned the Supreme Court of the State of Utah for certiorari, arguing that providing a passcode is not a testimonial communication, that the “foregone conclusion” exception applies in this case, and that the prosecutor's comments were permissible as a fair response to an issue that Valdez initiated.The Supreme Court disagreed with the State on all counts. The court held that verbally providing a cell phone passcode is a testimonial communication under the Fifth Amendment and that the "foregone conclusion" exception, which arises in cases where an “act of production” implicitly communicates information, does not apply. The court also rejected the State's "fair response" argument, concluding that the State had elicited the testimony about Valdez's refusal to provide his passcode before Valdez had raised any issue involving the contents of his phone. Consequently, the court affirmed the decision of the court of appeals. View "State v. Valdez" on Justia Law

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In this case, the defendant, Floyd Corry Robinson, argued that his sentence was unconstitutional because his counsel was ineffective and because the State suppressed evidence. Robinson brought his motion under Rule 22(e) of the Utah Rules of Criminal Procedure, which allows for correction of a sentence under certain circumstances. The Supreme Court of the State of Utah found that Robinson's claims did not fall under any of the categories listed in Rule 22(e) that would allow for a sentence correction. The court ruled that the district court correctly denied Robinson's motion, as his claims were not cognizable under Rule 22(e). The Supreme Court also rejected Robinson's argument that his filing should have been treated as a petition for post-conviction relief, not a Rule 22(e) motion. The court reasoned that Robinson's filing clearly invoked Rule 22(e) and did not suggest an intent to seek a different form of relief. The court therefore affirmed the district court's denial of Robinson's motion. View "State v. Robinson" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court denying Defendant's motion filed under Utah R. Civ. P. 60(b)(6), which allows a court to grant relief from a judgment under certain circumstances, holding that Defendant's challenge to his conviction could have been brought in a petition for post-conviction relief.Defendant pled guilty to two counts of attempted aggravated sexual abuse of a child. Defendant did not file a direct appeal and did not challenge his conviction under Utah's Post-Conviction Remedies Act (PCRA) but later filed a motion under Rule 60(b)(6) alleging ineffective assistance of counsel. The district court denied the motion, ruling that Rule 60(b)(6) was not the appropriate vehicle for Defendant to bring his claim. The Supreme Court affirmed, holding that the PCRA applied to Defendant's request to set aside his conviction based on his trial counsel's alleged conflict of interest. View "State v. Ogden" on Justia Law

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The Supreme Court affirmed Defendant's convictions of two counts of rape, one count of aggravated assault, and two counts of domestic violence in the presence of a child, holding that Defendant was not entitled to relief on his multiple claims of error.Specifically, the Supreme Court held (1) the district court did not abuse its discretion in not withholding from jury deliberations a video exhibit of Defendant's police interview; (2) Defendant failed to show that he was prejudiced by the alleged deficient performance of his trial counsel; and (3) the district court did not err in denying Defendant's motions for a mistrial and a new trial arising out of a child witness's breakdown on the witness stand. View "State v. Centeno" on Justia Law

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The Supreme Court affirmed the judgment of the district court rejecting the State's interpretation of Utah Const. art. I, section 8(1) to mandate that a judge deny bail to a defendant charged with a felony if that defendant is already serving probation on a felony conviction, holding that there was no error.Defendant was serving probation when he was charged with felony crimes in both Salt Lake and Davis counties. At the Davis County bail hearing the State argued that Utah Const. art. I, section 8(1) mandates that a judge deny bail to a defendant charged with a felony if that defendant is already serving probation on a felony conviction. The district court disagreed with the State's interpretation and set bail. The Supreme Court affirmed, holding that the district court correctly determined that it could grant Defendant bail. View "State v. Barnett" on Justia Law

Posted in: Criminal Law