Justia Utah Supreme Court Opinion Summaries

The State charged Defendant with official misconduct under Utah Code 76-8-201 and with witness tampering under Utah Code 76-8-508(1). At a preliminary hearing, the magistrate judge refused to bind Defendant over for trial, concluding that the State had not met its burden of presenting sufficient evidence to support a reasonable belief that Defendant had committed witness tampering or official misconduct. The court of appeals affirmed. The Supreme Court reversed, holding (1) the magistrate and court of appeals erred in weighing the evidence in search of the most reasonable inference; and (2) the State presented evidence supporting a reasonable belief that each offense in question was committed by Defendant. View "State v. Jones" on Justia Law

Petitioner’s son assaulted Petitioner’s co-worker. Petitioner was convicted of aggravated assault because phone records showed that calls were made Petitioner’s phone and his son’s phone just before and after the assault. Petitioner appealed, arguing that the trial court erred in admitting preliminary hearing testimony about the phone records from a detective who had dried before trial and that his lawyer’s objection on this point violated his constitutional right to the effective assistance of counsel. The court of appeals affirmed. The Supreme Court affirmed, holding (1) any error in admitting the detective’s testimony was not invited because there was no clear affirmative statement by counsel inviting the court to err; and (2) even if the trial court erred in admitting the detective’s testimony, Petitioner was not prejudiced by the admission of the testimony. View "State v. McNeil" on Justia Law

After a jury trial, Defendant was convicted of child kidnapping and sentenced to a term of ten years to life. During trial, Defendant moved to put on an expert in eyewitness testimony. The motion was denied because Defendant failed to establish that such testimony was reliable, but the jury was instructed on the issues surrounding eyewitness testimony. The court of appeals reversed, concluding that this case called for the retroactive application of the Supreme Court’s decision in State v. Clopten. In Clopten, the Court held that where eyewitness are identifying a stranger, expert eyewitness testimony meets the requirements of Utah R. Evid. 702 if certain established factors affecting accuracy are present. Prior to Clopten, there was a presumption against the admission of eyewitness expert testimony. The Supreme Court reversed, holding (1) Clopten applies retroactively to Defendant’s case; but (2) the trial court did not abuse its discretion under the Clopten standard in denying Defendant’s motion to admit eyewitness expert testimony. View "State v. Guard" on Justia Law

Defendant was charged with vaginally raping and orally and anally sodomizing his seven-year-old daughter. The State sought to introduce evidence pursuant to Utah R. Evid. 404(c) that Defendant had previously vaginally raped and orally and anally sodomized two other daughters. The district court ordered that the evidence not be admitted, concluding that the evidence demonstrated a propensity to commit the crime charged but did not pass muster under Utah R. Evid. 403 because it presented a danger of unfair prejudice that substantially outweighed its probative value. The Supreme Court reversed, holding (1) the district court abused its discretion by applying an incorrect legal standard and abused its discretion in how it assessed the similarities between the evidence of prior abuse and the current alleged abuse, as well as the potential prejudice from the evidence of prior abuse; and (2) the evidence of Defendant’s past child molestation conviction was admissible under Rule 403. View "State v. Cuttler" on Justia Law

Defendant was parked on the side of a highway with his hazard lights flashing when two sheriff’s deputies stopped to check on his welfare. The officers subsequently discovered marijuana in Defendant’s vehicle. The State charged Defendant with possession of marijuana and possession of drug paraphernalia. Defendant moved to suppress the evidence obtained from his vehicle. The district court denied the motion to suppress, ruling that the stop was justified by the community caretaking doctrine. After a jury trial, Defendant was convicted of the charges. Defendant appealed the denial of his motion to suppress. The Supreme Court affirmed, holding (1) the deputies seized Defendant when they pulled behind his parked vehicle with blue and red lights flashing; but (2) the community caretaking doctrine justified the stop under the facts of this case, and therefore, the seizure did not violate the Fourth Amendment. View "State v. Anderson" on Justia Law

After a jury trial, Defendant was convicted of aggravated murder and aggravated kidnapping, among other crimes. The Supreme Court affirmed Defendant’s convictions, holding (1) Defendant failed to establish that prosecutor committed misconduct by calling Defendant’s codefendant to testify when the codefendant had indicated an intention to invoke his Fifth Amendment privilege against self-incrimination, and therefore, the trial court did not abuse its discretion in denying Defendant’s motion for a mistrial; (2) because Defendant did not demonstrate prejudice from the prosecutor’s use of leading questions in questioning the codefendant, Defendant meet his burden of demonstrating prejudice for his unpreserved federal constitutional claim; and (3) Defendant’s lawyers were not ineffective for failing to move to merge the conviction for aggravated kidnapping with the conviction for aggravated murder because such a motion would have been futile. View "State v. Bond" on Justia Law

The State sought and received an order freezing more than $3 million of Frank and Joan Steed’s assets under Utah’s Asset Preservation Statute. The State subsequently filed criminal charges against the Steeds and sought a freeze order to ensure adequate funds would be available for the anticipated restitution award. The district court upheld the freeze order. Thereafter, the Steeds were convicted of three counts of failure to file tax returns and one pattern count of criminal fraud. The Steeds later filed a motion challenging the constitutionality of the Asset Preservation Statute, both facially and as applied. The district court denied the motion. Joan subsequently conceded the issue of technical mootness but argued that the mootness exception applied. The Supreme Court dismissed the case, holding that this case was moot and that Joan’s claims did not warrant the application of the mootness exception. View "State v. Steed" on Justia Law

Pursuant to a plea-in-abeyance agreement, Defendant pled no contest to charges of possession and use of a controlled substance and possession of drug paraphernalia. Defendant successfully complied with the terms of the agreement, and the justice court withdrew the plea of no contest and dismissed the two drug charges. Thereafter, Defendant filed an action under the Post-Conviction Remedies Act (PCRA) seeking to withdraw his plea in abeyance, arguing that his attorney provided ineffective assistance by improperly advising him that the abeyance plea carried no immigration consequences. The district court granted the State’s motion to dismiss, concluding that the court could not consider Defendant’s PCRA claim because the only relief available under the PCRA is to set aside a conviction, and the Legislature “did not intend a plea in abeyance to function as either a judgment or a conviction.” The Supreme Court affirmed, holding (1) the district court correctly concluded that Defendant did not qualify for relief under the PCRA because he was never convicted; and (2) the Court declines to exercise its constitutional power to fashion an alternate remedy because Defendant may obtain relief for the alleged ineffective assistance of counsel by filing a Utah R. Civ. P. 60(b)(6) motion in the justice court. View "Meza v. State" on Justia Law

After a jury trial, Defendant was found guilty of interference with an arresting peace officer and unlawful possession of another’s identification documents. Defendant appealed his conviction for unlawfully possessing another’s Social Security card, asserting that there was insufficient evidence to support a reasonable inference that he knew he was not entitled to possess the card. The court of appeals affirmed. The Supreme Court reversed, holding that the evidence presented to the jury was insufficient to sustain a reasonable inference that Defendant knew he was not entitled to possess the Social Security card. View "Salt Lake City v. Carrera" on Justia Law

After a jury trial, Defendant was convicted of twelve felony counts of unlawful discharge of a firearm. The charges stemmed from Defendant’s act of firing twelve shots at a house in a gang-related drive-by shooting. The trial court merged the twelve counts and sentenced Defendant on the basis of one conviction. The court of appeals reversed and ordered the trial court to resentence Defendant on all twelve convictions. The Supreme Court affirmed, holding that it was permissible for a jury to convict Defendant of twelve counts of unlawful discharge of a firearm in this case because the allowable unit of prosecution for unlawful discharge of a firearm is each discrete shot. View "State v. Rasabout" on Justia Law