Justia Utah Supreme Court Opinion Summaries

The mandatory joinder statute, Utah Code 76-1-401, prohibits the State from prosecuting a defendant in separate actions for conduct that may establish separate offenses under a “single criminal episode.” A “single criminal episode” is defined as “all conduct which is closely related in time and is incident to an attempt or an accomplishment of a single criminal objective.” Petitioner filed a motion to dismiss the wage crimes prosecution as barred by the mandatory joinder statute, arguing that the State violated section 76-1-401 by prosecuting him from 2011 to 2012 for wage crimes after having prosecuted and convicted him in 2009 and 2010 for tax crimes. Petitioner argued that the conduct underlying both prosecutions was part of a single criminal episode because it was closely related in time and incident to an attempt of accomplishment of the single criminal objective of misappropriation of money in his business setting. The district court denied the motion, and the court of appeals affirmed. The Supreme Court affirmed, holding that Defendant’s conduct did not have a single criminal objective and thus did not constitute a single criminal episode. View "State v. Rushton" on Justia Law

This case involved a claim for restitution by the victim of a sex crime committed by Defendant. The State alleged that Defendant’s crimes led to the victim’s depression, which impacted her ability to work and required counseling. The district court ordered Defendant to pay $12,934 in lost income in addition to restitution of the costs of the victim’s counseling. On appeal, Defendant challenged the lost income award, arguing that lost income is not available under the Crime Victims Restitution Act unless “the offense resulted in bodily injury to a victim.” The court of appeals affirmed. The Supreme Court reversed, holding that restitution for lost income was not available in this case because there was no allegation that Defendant’s offense “resulted in bodily injury” to the victim. View "State v. Wadsworth" on Justia Law

Defendant was charged and tried on four counts of theft and one count of attempted theft. After a jury trial, all jurors found Defendant guilty on all five counts. Defendant challenged his conviction under the Unanimous Verdict Clause of the Utah Constitution, alleging that there was lack of unanimity as to alternative factual theories advanced by the prosecution in support of some of the theft counts against him. Alternatively, Defendant alleged two other sets of trial errors as grounds for reversal. The Supreme Court affirmed, holding (1) precedent does not support the requirement of unanimity or sufficiency of the evidence for alternative, exemplary means of committing a crime, and the Utah Constitution imposes no such requirement; (2) the evidence was sufficient to support the jury’s verdict; and (3) Defendant otherwise failed to identify a basis for reversal of his convictions. View "State v. Hummel" on Justia Law

After a jury trial, Defendant was convicted of aggravated murder, obstructing justice, and five counts of discharging a firearm from a vehicle. On appeal, Defendant asked that his convictions be set aside based on an insufficiency of the evidence because a trio of witnesses changed their testimony after receiving deals from the State, and therefore, the testimony they each offered at trial was inherently dubious to the point that no reasonable jury could have relied on it to convict him. The Supreme Court affirmed, holding (1) the inconsistencies between the three witness’s pretrial statements and in-court testimony did not render their testimony apparently false; (2) moreover, ample additional evidence supported each of Defendant’s convictions; and (3) therefore, the trial court did not err, let alone plainly err, when it submitted Defendant’s case to the jury. View "State v. Prater" on Justia Law

Defendant was convicted of multiple counts of rape, sodomy, and sexual abuse of a twelve-year-old victim. The court of appeals reversed, concluding that the district court erred in admitting evidence of Defendant’s past misconduct. Specifically, the court held that the district court erred in failing to perform a “scrupulous examination” of the character evidence introduced by the State. The Supreme Court reversed the court of appeals and reinstated the judgment of conviction, holding (1) language in this Court’s prior opinions that speaks of “scrupulous examination” of character evidence under Utah R. Evid. 404(b) is hereby repudiated; (2) the district court properly admitted the character evidence at issue in this case; and (3) the district court properly refused to allow Defendant to present evidence of the victim’s sexual experience under Utah R. Evid. 412 and the Sixth Amendment. View "State v. Thornton" on Justia Law

In 2000, Appellant pleaded guilty to one count of rape of a child. In 2007, Appellant was released on parole. As a condition of parole, Appellant was required to successfully complete a sex offender program. The State subsequently sought to revoke Appellant’s parole on the grounds that Appellant failed to disclose his entire sexual history, including any uncharged sexual crimes, as part of his sex offender treatment. Appellant filed a petition for extraordinary relief claiming that the sex offender program unconstitutionally required him to incriminate himself. The district court granted summary judgment for the State. The Supreme Court reversed, holding that there are genuine disputes of material facts that preclude summary judgment. Remanded. View "Bennett v. Bigelow" on Justia Law

Defendant was convicted of one count each of aggravated murder and child kidnapping, each a first degree felony. Defendant was sentenced to two concurrent sentences of life imprisonment without parole for the convictions. The Supreme Court affirmed Defendant’s convictions, holding (1) Utah’s noncapital aggravated murder sentencing statute is not constitutionally deficient; (2) the district court did not abuse its discretion with respect to various evidentiary rulings Defendant challenged on appeal, including the court’s admission into evidence of two photographs, although in reaching that decision the Court abandoned its prior test that determined the threshold for the admission of potentially gruesome photographs; (3) the district court did not err in declining to merge Defendant’s child kidnapping conviction with his aggravated murder conviction; and (4) even assuming Defendant’s trial counsel provided constitutionally ineffective assistance, counsel’s performance did not prejudice Defendant. The sentencing court, however, incorrectly stated that the presumptive sentence for Defendant’s aggravated murder conviction was life in prison without parole. Remanded for the limited purpose of permitting the district court to clarify what impact is misapprehension of the law had on its sentencing decision. View "State v. Met" on Justia Law

Based on information received by a confidential informant (CI), police officers pulled over a vehicle in which Defendant was a passenger. Drugs were discovered during a search of the vehicle. Defendant was subsequently charged with possession of a controlled substance. Defendant filed a motion to compel the State to reveal the CI’s identity. The State claimed a privilege under Utah R. Evid. 505 and opposed the motion to compel. The district court elected to conduct an in camera interview to determine whether the CI possessed knowledge relevant to Defendant’s guilt or innocence, but the CI refused to appear. The district court concluded that Rule 505 did not require it to dismiss the charges against Defendant. Thereafter, Defendant was convicted of possession of a controlled substance. The Supreme Court reversed, holding that the district court applied the incorrect legal standard when it ruled that Rule 505 did not require dismissal of the charges against Defendant. Remanded. View "State v. Nielsen" on Justia Law

Suspecting that his ex-girlfriend was planning to steal a motor home, Defendant snatched his ex-girlfriend’s purse to deliver the evidence to the police. Defendant’s conduct led to a fight between him and his ex-girlfriend. The State charged Defendant with aggravated robbery, among other crimes. After a jury trial, Defendant was found guilty. The Supreme Court affirmed, holding (1) the trial court did not err when it declined to reduce Defendant’s conviction from aggravated robbery to robbery; and (2) the trial court did not abuse its discretion in not granting a continuance to permit Defendant to subpoena additional defense witnesses. View "State v. Mackin" on Justia Law

Layton City charged Defendant with driving under the influence, driving on a denied license, and leaving the scene of a property-damage accident. Defendant filed a motion to suppress the evidence discovered after police officers investigating a hit-and-run accident entered a private residence with neither permission nor a warrant. The district court granted the motion, concluding that, even though the officers were in the process of obtaining a search warrant at the time they entered the house, the inevitable-discovery exception to the exclusionary rule did not apply in this case. The court of appeals reversed, concluding that the City established the applicability of the inevitable-discovery exception to the warrantless search. The Supreme Court reversed the decision of the court of appeals and affirmed the district court’s order granting Defendant’s suppression motion, holding that the district court correctly determined that the City’s evidence was too speculative to establish inevitable discovery, and therefore, the City failed to meet its burden of establishing the inevitable-discovery exception. View "Brierley v. Layton City" on Justia Law