Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's convictions of ten counts of forcible sexual abuse and one count of object rape for sexually abusing two of his sisters-in-law, holding that Defendant's counsel did not provide ineffective assistance, the district court did not err in its evidentiary rulings, the denial of Defendant's motion for a mistrial was not an abuse of discretion, and that Defendant did not suffer prejudice when Defendant's sisters-in-law were referred to as "victims."Specifically, the Court held (1) trial counsel did not provide constitutionally defective representation when he failed to move to sever the charges regarding each victim so that Defendant could have two separate trials; (2) trial counsel's failure to object to certain testimony was not unreasonable; (3) the district court did not err by admitting testimony that Defendant claimed was protected by the attorney-client privilege; and (4) Defendant was not prejudiced when the court and a witness referred to Defendant's sisters-in-law as victims. View "State v. Vallejo" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder, holding that any error the trial court committed when it refused to allow a claim of perfect self-defense was harmless and that the trial court did not abuse its discretion when it denied Defendant's motion for a mistrial.On appeal, Defendant argued that the trial court erred when it prevented him from arguing perfect self defense and that the trial court abused its discretion when it refused to declare a mistrial after the prosecutor asked Defendant to demonstrate the shooting using a facsimile gun. The Supreme Court affirmed, holding (1) the trial court's failure to give a perfect self-defense instruction was harmless under any formulation of the prejudice standard; and (2) under the circumstances of this trial the trial court did not err in denying Defendant's motion for a mistrial. View "State v. Silva" on Justia Law

The Supreme Court affirmed Defendant's conviction of three counts of possession of a firearm by a restricted person in violation of Utah Code 76-10-503(3), holding that the district court did not err in refusing the instruct the jury on an innocent possession defense.A jury convicted Defendant of violating section 76-10-503(3) after police officers responding to a domestic complaint found Defendant in his backyard carrying a rifle. Before trial, Defendant requested an innocent possession jury instruction, but the district court denied the request. On appeal, Defendant argued that the felon-in-possession statute included an innocent possession defense. The Supreme Court disagreed, holding (1) the felon-in-possession statute does not implicitly provide an innocent possession defense; and (2) case law does not require an innocent possession defense. View "State v. Sanders" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of one count of threatening with or using a dangerous weapon in a fight or quarrel, holding that there was no error in the district court's judgment.Defendant, a detective with the Unified Police Department, was bird hunting when he angrily confronted another hunter's group with his service weapon drawn and held at his side. On appeal, Defendant argued that the district court erred in treating the relevant statute's exception for persons acting in self-defense and peace officers in performance of their duties as affirmative defenses rather than elements of the offense. The Supreme Court affirmed, holding (1) under Utah Code 76-10-506, self-defense and acting as a peace officer in performance of duties are affirmative defenses, not elements of the offense; (2) the declaration from a juror submitted by Defendant in support of his motion for a new trial was inadmissible under Utah R. Evid. 606(b); and (3) the district court's deadlock instruction was not unconstitutionally coercive. View "State v. Bess" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing on summary judgment Plaintiff's claims against Box Elder County and the Box Elder County Sheriff's Office, including claims of violations of his rights to due process and bail, holding that the court did not err in dismissing the bail clause claims but erred in dismissing the due process claims.Plaintiff was held in the Box Elder County Jail for seventeen days on a probable cause determination that he was driving under the influence, but no evidence showed that he was actually driving impaired, and Plaintiff was never brought before a judge for his initial appearance or formally charged with any crimes. The district court concluded that Plaintiff had not suffered a flagrant violation of his constitutional rights and that he could not identify a specific municipal employee who had violated his rights. The Supreme Court held (1) Plaintiff's bail clause claims were properly dismissed because Plaintiff failed to demonstrate that the bail clause was self-executing; but (2) the court incorrectly applied the standard for determining when a municipal employee is liable for damages for a constitutional violation in dismissing Plaintiff's due process claims. View "Kuchcinski v. Box Elder County" on Justia Law

The Supreme Court affirmed the district court's summary judgment decision denying Appellant's petition for relief under the Post-Conviction Remedies Act (PCRA), Utah Code 78B-9-101, et seq., holding that Appellant failed to satisfy his burden of persuasion on appeal.Appellant was convicted of aggravated burglary, theft, and criminal mischief. Appellant later filed a petition for post-conviction relief arguing that he was entitled to relief under the PCRA. The district court granted summary judgment for the State. On appeal, Appellant argued that his due process rights under the Utah Constitution were violated when certain evidence was destroyed in accordance with rule 4-206 of the Utah Code of Judicial Administration. The Supreme Court affirmed, holding (1) Appellant failed to comply with any portion of the PCRA that could offer him relief; and (2) Appellant failed to demonstrate that the disposal of evidence violated his state due process rights. View "Sandoval v. State" on Justia Law

The Supreme Court reversed the decision of the district court summarily dismissing Appellant’s petition for post-conviction relief, holding that the district court erred in determining that, as a matter of undisputed fact and law, Appellant was not prejudiced by his defense counsel’s conduct at either the guilt or sentencing phases of Appellant’s trial.In 1985, Appellant was sentenced to death for murder. In 2011, Appellant’s current counsel located two witnesses who testified in the murder case, and obtained their sworn declarations that the police threatened them if they did not cooperate in the case against Appellant, that their testimony was coached, and that they were instructed to lie under oath about benefits they received from the State. Appellant filed a petition for post-conviction relief based upon these revelations, but the district court dismissed the petition. The Supreme Court reversed and remanded for an evidentiary hearing, holding that Appellant demonstrated a genuine dispute of material fact as to whether he was prejudiced. View "Carter v. State" on Justia Law

In this action brought by the State seeking to overturn a conviction it recently obtained, the Supreme Court vacated the order of the district court denying the State’s Utah. R. Civ. P. 60(b) motion in the underlying criminal proceeding, holding that the district court had jurisdiction to adjudicate the State’s motion and that rule 60(b) provided the mechanism through which the State may bring its challenge.After final judgment had been entered against Bela Fritz, the State returned to the district court claiming Fritz had misled it about his identity. The State filed a motion under rule 60(b) seeking to vacate the conviction, sentence, and judgment. The district court denied the motion, concluding that following imposition of a valid sentence, a district court loses subject matter jurisdiction over a criminal case and that the State needed to proceed under the Post-Conviction Remedies Act. The State filed this petition for extraordinary relief asking that the Supreme Court direct the district court to exercise jurisdiction over the State’s motion for relief under rule 60(b). The Supreme Court exercised its discretion and granted the writ, thus vacating the order denying the State’s motion and instructing the district court to exercise jurisdiction over the matter. View "State v. Honorable Ann Boyden" on Justia Law

The Supreme Court reversed Defendant’s conviction under Utah’s witness retaliation statute, Utah Code 76-8-508.3, holding that the statute does not criminalize threats a person makes regarding a witness outside the witness’s presence and without an intention to have the threat communicated to the witness.Section 76-8-508.3 makes it a crime to direct a threat of harm or a harmful action against a witness or a person closely associated with that witness as retaliation against that witness. After Defendant was convicted, he challenged his conviction on the ground that the witnesses that were the subject of the alleged threat were not present when Defendant made the threat. The court of appeals affirmed. The Supreme Court reversed, holding (1) the witness retaliation statute criminalizes only those threats that the threat-maker intended to be communicated to the witness; and (2) therefore, the court of appeals incorrectly interpreted the requirements of the statute. View "State v. Trujillo" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of one count of stalking and one count of threat of violence, holding that neither issue raised by Defendant on appeal was preserved nor amounted to plain error.On September 12, 2014, Salt Lake City filed an information in justice court charging Defendant with threat of violence based on an incident that occurred on September 7, 2014. While that case was pending, the City charged Defendant in the district court with stalking and threat of violence. The threat of violence charge was based on an alleged threat that occurred on September 30, 2014. The stalking charge was based on alleged conduct occurring throughout September 2014. Defendant was convicted on both counts. On appeal, Defendant argued that the district court prosecution was barred by the earlier justice court prosecution or, alternatively, that the district court plainly erred in failing to merge the convictions at sentencing. The Supreme Court affirmed, holding (1) neither of Defendant’s arguments was adequately preserved in the proceedings below; and (2) because of the unsettled nature of this area of law, any error was not plain error. View "Salt Lake City v. Josephson" on Justia Law