Justia Utah Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder. The jury imposed a sentence of life without parole. On appeal, the Supreme Court remanded the case for the trial court to conduct a rule 23B hearing addressing Defendant’s claims of ineffective assistance of counsel. The Court stayed the remainder of Defendant’s appeal pending the outcome of those proceedings. The Supreme Court affirmed Defendant’s conviction, holding (1) the trial court did not abuse its discretion in admitting certain DNA and mtDNA evidence; (2) Defendant’s counsel did not provide ineffective assistance; and (3) even if the remainder of Defendant’s claims established errors, any such errors would not have resulted in a reasonable likelihood of a different outcome. View "State v. Griffin" on Justia Law

In 2002, Appellant was convicted of murder. The Supreme Court affirmed the conviction on appeal. Appellant later filed a petition under Part 3 of the Post-Conviction Remedies Act seeking testing on previously untested items from the murder scene and arguing that the DNA testing would prove his factual innocence. The State subsequently filed a response asking the district court to dismiss Appellant’s petition. Before Appellant had an opportunity to oppose the State’s filing, the district court dismissed Appellant’s petition on the grounds that Appellant failed to establish a non-tactical reason for declining DNA testing at trial. Thereafter, the district court denied Appellant’s motion for reconsideration. The Supreme Court reversed, holding that the district court erred in refusing to allow Defendant an opportunity to file a response to the State’s opposition to his petition under Utah R. Civ. P. 65C. Remanded. View "Gordon v. State" on Justia Law

In 2002, Appellant was convicted of murder. The Supreme Court affirmed the conviction on appeal. Appellant later filed a petition under Part 3 of the Post-Conviction Remedies Act seeking testing on previously untested items from the murder scene and arguing that the DNA testing would prove his factual innocence. The State subsequently filed a response asking the district court to dismiss Appellant’s petition. Before Appellant had an opportunity to oppose the State’s filing, the district court dismissed Appellant’s petition on the grounds that Appellant failed to establish a non-tactical reason for declining DNA testing at trial. Thereafter, the district court denied Appellant’s motion for reconsideration. The Supreme Court reversed, holding that the district court erred in refusing to allow Defendant an opportunity to file a response to the State’s opposition to his petition under Utah R. Civ. P. 65C. Remanded. View "Gordon v. State" on Justia Law

After a jury trial held in 1999, Appellant was convicted of murder and tampering with evidence. The convictions were affirmed on appeal and upheld on multiple postconviction challenges in both state and federal court. Appellant here filed a petition for postconviction DNA testing, claiming that DNA testing will show his factual innocence. The district court denied Appellant’s petition, concluding that the DNA testing did not have the potential to produce new, noncumulative evidence that would establish Appellant’s factual innocence under Utah Code 78B-9-301(2)(f). The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court’s analysis of the operative terms of the statute was only partially in accordance with the law. Remanded. View "Meinhard v. State" on Justia Law

After a jury trial held in 1999, Appellant was convicted of murder and tampering with evidence. The convictions were affirmed on appeal and upheld on multiple postconviction challenges in both state and federal court. Appellant here filed a petition for postconviction DNA testing, claiming that DNA testing will show his factual innocence. The district court denied Appellant’s petition, concluding that the DNA testing did not have the potential to produce new, noncumulative evidence that would establish Appellant’s factual innocence under Utah Code 78B-9-301(2)(f). The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court’s analysis of the operative terms of the statute was only partially in accordance with the law. Remanded. View "Meinhard v. State" on Justia Law

Monsour Al Shammari, a citizen of Saudia Arabia, was arrested and charged with rape. The Royal Consulate of Saudia Arabia provided the cash funds to post bail. Al Shammari subsequently attempted to cross the border into Mexico but was detained by the United States Customs and Border Patrol. Thereafter, Al Shammari failed to appear for a scheduled hearing, and the district court ordered the cash bail forfeited. Al Shammari moved to set aside the order of forfeiture, contending that the forfeiture was procedurally deficient because the Consulate was not given notice. The district court ordered the bail forfeited, concluding that the Consulate was not a “surety” for purposes of Chapters 20 and 20b of Title 77 of the Utah Code. The Supreme Court denied the Consulate’s petition for extraordinary relief, concluding that the Consulate was not a surety that was constitutionally or statutorily entitled to notice. View "Royal Consulate v. Hon. Pullen" on Justia Law

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