Justia Utah Supreme Court Opinion Summaries

This case involved a certification and statement of facts requesting a grand jury filed by the Salt Lake County District Attorney. After a hearing, a special panel of five district judges denied the State’s request, finding that the State had not established good cause to summon a grand jury. Thereafter, the State filed a petition for extraordinary relief in the Supreme Court, claiming that the panel abused its discretion by denying the State’s request. The Supreme Court denied the State’s petition for extraordinary relief, holding (1) the Court’s power to issue extraordinary writs gives it jurisdiction to review the panel’s decisions; but (2) the panel did not abuse its discretion in this case, as it acted exactly as it was statutorily directed to act and employed its discretion with care and impartiality. View "State v. Hon. Christiansen" on Justia Law

Defendant was charged with eleven counts related to his alleged sexual abuse of C.E. The State requested that a magistrate bind Defendant over for trial. After a hearing, the magistrate concluded that the evidence was so contradictory, inconsistent, and unbelievable that she need not “give credence” to C.E.’s testimony. Because the case depended “solely on the testimony of [C.E.]”, the magistrate granted Defendant’s motion to dismiss the charges, finding that the prosecution failed to present sufficient evidence to support a reasonable belief that Defendant committed the crimes charged. The First Circuit reversed the magistrate’s decision, holding (1) the magistrate exceeded her discretion in disregarding C.E.’s testimony because there was at least a reasonable inference from the evidence that C.E. was telling the truth; and (2) the magistrate exceeded her discretion in refusing to bind Defendant over for trial because C.E.’s testimony described daily sexual abuse over a four-year period. View "State v. Schmidt" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated murder and one count of theft by receiving a stolen motor vehicle. Defendant was sentenced to life in prison without the possibility of parole on the aggravated murder counts. Defendant appealed, raising several claims of ineffective assistance of counsel. The Supreme Court granted Defendant’s motion for remand and stayed the appeal. After a hearing, the district court rejected all of Defendant’s claims. The Supreme Court affirmed Defendant’s convictions, holding that defense counsel either did not perform deficiently or that Defendant failed to show prejudice stemming from defense counsel’s alleged deficiencies. View "State v. Nelson" on Justia Law

In 1993, Appellant was convicted of sodomizing his girlfriend’s sons and with sexually assaulting a neighbor’s child. In 2009, Appellant filed a petition for post-conviction relief alleging that counsel provided ineffective assistance by failing to inform him about a plea bargain the State allegedly offered before trial. The district court dismissed the petition, concluding that it was time-barred under the Post-Conviction Remedies Act (PCRA). The Supreme Court affirmed the dismissal of most of Appellant’s claims, but before it could issue its decision, the U.S. Supreme Court decided Lafler v. Cooper and Missouri v. Frye. The Utah Supreme Court ultimately vacated the dismissal on the narrow issue of whether these decisions created a new cause of action for Appellant under the PCRA. Appellant pursued a claim based on these decisions. The district court dismissed Appellant’s claim. The Supreme Court affirmed, holding that because Lafler and Frye announced a new rule not dictated by precedent existing at the time Appellant’s conviction or sentence became final, they did not give rise to a new cause of action under the PCRA. View "Winward v. State" on Justia Law

In 1993, Appellant was convicted of sodomizing his girlfriend’s sons and with sexually assaulting a neighbor’s child. In 2009, Appellant filed a petition for post-conviction relief alleging that counsel provided ineffective assistance by failing to inform him about a plea bargain the State allegedly offered before trial. The district court dismissed the petition, concluding that it was time-barred under the Post-Conviction Remedies Act (PCRA). The Supreme Court affirmed the dismissal of most of Appellant’s claims, but before it could issue its decision, the U.S. Supreme Court decided Lafler v. Cooper and Missouri v. Frye. The Utah Supreme Court ultimately vacated the dismissal on the narrow issue of whether these decisions created a new cause of action for Appellant under the PCRA. Appellant pursued a claim based on these decisions. The district court dismissed Appellant’s claim. The Supreme Court affirmed, holding that because Lafler and Frye announced a new rule not dictated by precedent existing at the time Appellant’s conviction or sentence became final, they did not give rise to a new cause of action under the PCRA. View "Winward v. State" on Justia Law

Appellant was convicted of two counts of aggravated murder and related crimes. The Supreme Court affirmed. Thereafter, Appellant filed a petition for relief under the Post-Conviction Remedies Act (PCRA), claiming that newly discovered evidence in the form of testimony from two new witnesses would exonerate him and that the State violated his due process rights by knowingly introducing perjured testimony and fabricating evidence at trial. The district court dismissed Appellant’s PCRA claims. The Supreme Court affirmed, holding (1) because Appellant failed to demonstrate that no reasonable jury could enter a judgment of conviction in light of the new testimony, Appellant’s newly discovered evidence claims failed on their merits; (2) Appellant’s due process claims were procedurally barred because they could have been but were not brought at trial or on appeal; and (3) the district court did not abuse its discretion in denying Appellant’s motions for discovery and to amend his PCRA pleadings. View "Pinder v. State" on Justia Law

Defendant was charged with aggravated murder, child kidnapping, and rape of a child. The case was assigned to Judge Kouris. Two weeks before the preliminary hearing, defense counsel filed a petition to evaluate Defendant’s competency to stand trial. Judge Kouris was scheduled to preside over Defendant’s competency evaluation. Defendant filed a motion to transfer adjudication of the competency petition to another judge, arguing that his competency evaluation must be adjudicated by a different judge because Judge Kouris had sat as magistrate in the case. The district court denied the motion to transfer. Defendant then moved to disqualify Judge Koruis, arguing that the judge created an appearance of bias. The district court denied the motion. The Supreme Court affirmed, holding (1) the disqualification issue became moot when Judge Kouris was transferred to a different court docket, causing this case to be reassigned during the pendency of this appeal; and (2) a district court judge retains the authority to act as both a magistrate and a judge in the same criminal case. View "State v. Black" on Justia Law

Appellant pleaded guilty to first-degree murder in 1988. Appellant later filed a motion to withdraw his plea. The district court denied the motion on the merits. The Supreme Court affirmed. In 2014, Appellant filed a motion to reinstate his right to appeal under Utah R. App. P. 4(f), claiming that his counsel had rendered ineffective assistance in advising him to accept the plea. The district court concluded that the allegations did not satisfy the criteria set forth by rule 4(f). Appellant’s appeal was transferred to the court of appeals under Utah R. App. P. 42(a). Appellant argued that the appeal was not subject to transfer. The Supreme Court issued an order temporarily recalling the transfer of this appeal for the purpose of determining whether it was within the Court’s exclusive jurisdiction. The Supreme Court transferred this appeal back to the court of appeals, concluding that this appeal was not within the Court’s exclusive appellate jurisdiction because the decision from which Appellant’s appeal was brought only denied a postjudgment request to reinstate the right to appeal, and Appellant’s appeal of that decision did not constitute a direct challenge to his conviction. View "State v. Smith" on Justia Law

After a jury trial, Defendant was convicted of aggravated murder, aggravated burglary, possession of a weapon by a restricted person, and obstruction of justice. The Supreme Court affirmed, holding (1) the trial court erred in denying Defendant’s request for lesser-included-offense jury instructions on several variants of unintentional homicide, but the error was harmless; (2) the trial court did not err by preventing Defendant from asking twelve questions during voir dire; (3) evidence that Defendant was arrested with a stolen rifle in his car one month after the murder was properly admitted; and (4) the trial court did not abuse its discretion in refusing to sever the weapons charge from the other charges. View "State v. Reece" on Justia Law

Defendant was charged with multiple counts of securities fraud and theft based on his alleged operation of a Ponzi scheme. Defendant filed a motion to dismiss, claiming that eight of the ten charges were time barred under the applicable statutes of limitations. The district court denied the motion, concluding that securities fraud and theft are continuing offenses. The Supreme Court reversed, holding that the district court’s conclusion was in error because neither securities fraud nor theft is a continuing offense. Remanded for the district court to re-evaluate the timeliness of the charges. View "State v. Taylor" on Justia Law