Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s conviction for offering escort services without a valid license, holding that Defendant’s constitutional claims were either inadequately briefed or not properly raised in the district court.Defendant had an escort services license from Midvale City when she met an undercover Salt Lake City police officer in Salt Lake and asked him for a “show-up” fee, but Defendant did not have a license from Salt Lake City at the time. Because State law authorizes any municipality to impose licensing requirements on employees of sexually oriented businesses, the resulting regulatory scheme requires escorts to obtain licenses in each jurisdiction in which they seek to operate. On appeal from her conviction, Defendant argued that the imposition of multiple licensing requirements violates her First Amendment and Equal Protection rights. The Supreme Court affirmed, holding (1) Appellant did not preserve her Equal Protection claim in the district court; and (2) Appellant did not adequately brief her First Amendment challenge on appeal. View "Salt Lake City v. Kidd" on Justia Law

The Supreme Court reversed the district court’s decision denying Appellant’s amended petition under the Post-Conviction Remedies Act (PCRA) seeking relief from his convictions, holding that the district court erred in concluding that the claim in Appellant’s amended petition did not satisfy Utah R. Civ. P. 15(c) and so was time barred under the PCRA.Before the district court ruled on the merits of Appellant’s original petition, the district court appointed pro bono counsel, but only after the one-year statute of limitations period on Appellants’ PCRA petitions had expired. Pro bono counsel then amended Appellant’s petition, with permission from the court, by removing all previous claims from the original petition and replacing them with an ineffective assistance of counsel claim. The district court dismissed the amended petition on the grounds that it was time-barred under the PCRA. The Supreme Court reversed and remanded the case, holding that the district court (1) did not err in concluding that rule 15(c) applies to proposed amendments made to PCRA petitions; but (2) erred in concluding that Appellant’s amended petition did not satisfy rule 15(c). View "Noor v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating the juvenile judge’s bindover order in this case involving a juvenile’s criminal conduct, holding that it was error to excuse Defendant from preserving his claim of judicial bias.The State charged Defendant with three first-degree felonies in juvenile court. The juvenile judge bound over Defendant, who was sixteen years old when he committed the offenses, to the district court to be tried as an adult. Defendant then pled guilty to lesser charges. While serving his prison sentence, Defendant moved to reinstate the time to appeal his bindover order, which the district court granted. Defendant then argued on appeal that the juvenile judge should have recused herself from his case due to judicial bias. The court of appeals agreed and vacated the bindover order without requiring Defendant to show either that he had preserved his judicial bias claim in the trial court or that an exception to preservation applied. The Supreme Court reversed, holding that Defendant’s judicial bias claim was not exempt from the preservation requirement. View "State v. Van Huizen" on Justia Law

The Supreme Court affirmed Defendant’s conviction of rape and forcible sexual assault of his wife, holding that a single error occurred below, and the error was not prejudicial.Specifically, the Court held (1) Defendant failed to preserve for appeal his argument that the trial judge violated his constitutional rights by making comments to the jury pool about the O.J. Simpson case; (2) the trial court did not err in concluding that alleged sexual partner evidence created a danger of unfair prejudice that substantially outweighed the evidence’s probative value; (3) the trial court did not err in admitting evidence of Defendant’s prior bad acts or limiting defense counsel’s cross-examination of the victim on that point; and (4) Defendant was not prejudiced by his trial counsel’s failure to object to the trial judge’s comments to the jury. View "State v. Beverly" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of child abuse homicide, holding that Defendant’s challenges to expert testimony provided in his case would not receive consideration and that the district court properly denied Defendant’s motion to suppress. The Court, however, took the opportunity provided in this case to rebuke sole reliance on the factors set forth in Salt Lake City v. Carter, 664 P.2d 1168 (Utah 1983) for the determination of whether an individual is in custody for purposes of Miranda v. Arizona, 384 U.S. 436 (1966) and clarified the role these factors play going forward in order to bring courts in lockstep with the United States Supreme Court as to this determination. View "State v. Fullerton" on Justia Law

Travis Tulley claimed that while he was napping on Victim’s couch, Victim held a knife to his forehead and attempted to grope his genitals. In response, Tulley violently assaulted Victim, a 71-year-old man. Tulley wanted to introduce evidence at trial of Victim’s prior sexual misconduct. The district court excluded much of that evidence, but held that Tulley could present some of it in a “sanitized” form. Tulley also asked the district court to instruct the jury that he would be entitled to defend himself if he was trying to prevent “forcible sexual abuse.” The district court declined Tulley’s request. The jury convicted Tulley of reckless aggravated abuse of a vulnerable adult and interference with an arresting officer. Tulley received a sentence enhancement because he qualified as a habitual violent offender. Granting Tulley's petition for certiorari review, the Utah Supreme Court concluded the district court correctly excluded evidence of Victim’s prior sexual misconduct and correctly instructed the jury. Furthermore, the Court determined Utah’s aggravated abuse statute was not unconstitutionally vague and concluded Tulley did not meet his burden of establishing that Utah’s habitual violent offender statute violated either the Utah Constitution’s cruel and unusual punishment clause or the double jeopardy clause. View "Utah v. Tulley" on Justia Law

In this criminal case, the Supreme Court held that the court of appeals erred in accumulating errors that, standing alone, had no potential to cause harm, and thus reversed the court of appeals’ determination of cumulative error and remanded the case for the court of appeals to make a meritorious determination on Defendant’s motion to suppress.Defendant was convicted of two drug-related counts. After Defendant was convicted, the trial court stated that it was considering granting a new trial because of defense counsel’s ineffectiveness and appointed separate conflict counsel to represent Defendant on the issues it raised. The trial court declined to grant a new trial. Defendant appealed, asserting that his trial counsel provided ineffective assistance during the jury selection and motion stages and that the trial court erred in its dealings with conflict counsel. The court of appeals concluded that none of Defendant’s three claims of error warranted reversal on its own but that the cumulative effect of the errors warranted a new trial. The Supreme Court reversed, holding (1) the errors could not cumulate into reversible error; and (2) because the trial court did not determine whether the motion to suppress was meritorious, the case must be remanded to the court of appeals to make this determination. View "State v. Martinez-Castellanos" on Justia Law

The Supreme Court dismissed the interlocutory appeal brought by Defendant challenging the district court’s decision to quash a subpoena Defendant sought seeking against his alleged victim to testify at his preliminary hearing, holding that the decision had been mooted and that the Court lacked jurisdiction to address the district court’s decision to bind Defendant over for trial.Defendant appealed the district court’s decision to quash the subpoena but did not appeal the district court’s determination that probable cause existed for him to face trial. Because the decision Defendant appealed had been mooted by the subsequent bindover and the Supreme Court lacked jurisdiction to consider the bindover decision, the Court dismissed this appeal and remanded the case. View "State v. Hernandez" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of reckless aggravated abuse of a vulnerable adult and interference with an arresting officer, holding that the district court did not err in excluding evidence of the victim’s prior sexual misconduct and correctly instructed the jury.Defendant received a sentence enhancement for his convictions because he qualified as a habitual violent offender. On appeal, Defendant argued that the district court erred in excluding the victim’s prior sexual misconduct evidence and in instructing the jury. The Supreme Court found no error as to these issues. Defendant also argued that Utah’s aggravated abuse of a vulnerable adult statute was unconstitutionally vague and that Utah’s habitual offender statute violated the Utah Constitution’s cruel and unusual punishment clause and the double jeopardy clause. The Supreme Court disagreed, holding that Utah’s aggravated abuse statute is not unconstitutionally vague and that Utah’s habitual violent offender statute is constitutional. View "State v. Tulley" on Justia Law

In this murder case, the Supreme Court clarified the correct standard for extreme emotional distress.Defendant was convicted of first-degree murder for viciously torturing his girlfriend, ultimately causing her death. Defendant argued that he was under extreme emotional distress at the time of the murder. On appeal, the court of appeals concluded that the trial court abused its discretion by not admitting statements under Utah R. Evid. 106 that Defendant made to a detective that he argued would have supported his claim for a reduced charge based on special mitigation for extreme emotional distress but that the error was harmless. The Supreme Court vacated the portions of the court of appeals’ decision that dealt with Rule 106 and the standard for extreme emotional distress, clarified the correct standard for extreme emotional distress, and affirmed the harmlessness determination of the court of appeals on affirmative grounds. View "State v. Sanchez" on Justia Law