Justia Utah Supreme Court Opinion Summaries

In two separate cases, the State charged Defendant with multiple counts of communications fraud and one count of a pattern of unlawful activity. The district court (1) dismissed the first case on statute-of-limitations grounds after concluding that communications fraud is not a continuing offense; and (2) dismissed the second case as an improper attempt to prosecute Defendant for the same substantive offense as in the previous case. The State appealed both cases. The Supreme Court affirmed the dismissal of both cases, holding (1) in the first case, the statute of limitations had run for the charged crimes; and (2) in the second case, the State failed to separately challenge the district court’s dismissal, and therefore, the dismissal of the second case is also affirmed. View "State v. Kay" on Justia Law

Defendant was seventeen and a half when he murdered a staff member of the residential treatment center for youth where he was temporarily residing. Defendant pleaded guilty to aggravated murder. The jury, after considering the mitigating circumstances inherent to Defendant’s youth, nevertheless sentenced him to life imprisonment without the possibility of parole. Defendant appealed, bringing numerous constitutional challenges to his sentence and alleging that his counsel provided ineffective assistance during the sentencing proceeding. The Supreme Court affirmed, holding that Defendant’s sentence was constitutional and that Defendant failed to demonstrate that he received ineffective assistance of counsel. View "State v. Houston" on Justia Law

Appellant was seventeen and one-half years old when he murdered the victim in this case. Appellant pleaded guilty to aggravated murder, and the parties proceeded to a sentencing hearing before a jury. Following the sentencing hearing, eleven of the twelve jurors voted to sentence Appellant to life imprisonment without the possibility of parole. Appellant appealed, bringing several constitutional challenges to his sentence under Utah R. Crim. P. 22(e). The Supreme Court affirmed the jury’s sentence, holding (1) Appellant’s sentence was constitutional; and (2) Appellant failed to demonstrate that he received ineffective assistance of counsel. View "State v. Houston" on Justia Law

A police officer filed a citation issued against Appellant for an open container offense in justice court, thus initiating a criminal case against Appellant. After Appellant failed to appear or forfeit bail on her justice court charge, prosecutors filed an information in district court charging Appellant with DUI, an alcohol-restricted driver offense, and an open container violation. Appellant subsequently paid her justice court fine, thus accepting a conviction in justice court on the open container offense. Despite the justice court conviction, prosecutors moved forward on the information filed in the district court. Defendant moved to dismiss. The district court (1) dismissed the open container charge, determining that the Double Jeopardy Clause prohibited a serial prosecution on that charge; but (2) denied Appellant’s motion to dismiss the other two charges, concluding that the charges were not precluded by Utah Code 76-1-403, which adopts a principle of criminal claim preclusion for offenses arising out of a “single criminal episode.” The Supreme Court affirmed the denial of Appellant’s motion to dismiss the remaining two charges, holding that the preclusion principle in section 403 was inapplicable in this case because there was no “prosecuting attorney” involved in Appellant’s first offense. View "State v. Ririe" on Justia Law

Appellant was convicted of first-degree murder and sentenced to death. After appealing, Appellant began pursuing postconviction relief. More than two years after Appellant’s second petition for postconviction relief under Utah’s Post Conviction Remedies Act (PCRA) was denied, Appellant filed a Utah R. Civ. P. 60(b) motion for relief from the denial of the second petition on the basis of newly discovered evidence. The district court denied Appellant’s Rule 60(b) motion as untimely. Appellant subsequently filed a new petition for postconviction relief based upon the same newly discovered evidence presented in his Rule 60(b) motion. The clerk of court, however, did not assign the third petition a new case number but instead filed it under the case number already assigned to the second petition. As a result, the court granted the State’s motion to dismiss the third petition for lack of jurisdiction. Appellant appealed from both the denial of his Rule 60(b) motion and the dismissal of his third petition. The Supreme Court (1) affirmed the district court’s denial of Appellant’s Rule 60(b) motion; but (2) reversed the court’s dismissal of the third petition, holding that the district court had subject matter jurisdiction over the third petition regardless of the case number assigned to it. View "Carter v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree rape. The Supreme Court reversed, holding (1) trial counsel was ineffective for failing to object to a jury instruction misstating the requirement of mens rea as applied to the elements of first-degree rape; and (2) the statutory standard for nonconsent under Utah Code 76-5-406 does not establish the sum and substance of all circumstances amounting to nonconsent but simply prescribes the circumstances in which the legislature forecloses a jury finding of consent as a matter of public policy. The Court also clarified and the standard for granting a defendant’s request for a victim’s medical records under Utah R. Crim. P. 14(b). View "State v. Barela" on Justia Law

Defendant entered a conditional guilty plea to five charges of sexual exploitation of a minor. The charges arose from the discovery of child pornography on Defendant’s laptop computer. Defendant appealed, challenging several of the district court’s pretrial rulings, many of them related to the propriety of law enforcement’s use of the Wyoming Toolkit, a computer program and database used to identify child pornography shared over the Internet with peer-to-peer (P2P) file sharing networks. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress the evidence of child pornography found on Defendant’s computer, as the government’s use of the Wyoming Toolkit to identify child pornography in files shared on a P2P network is not a search; (2) the district court did not abuse its discretion in denying Defendant’s motion to compel discovery of the Wyoming Toolkit; (3) the classifications created by Utah’s sexual exploitation of a minor statute are constitutional, and Defendant lacked standing to challenge the constitutionality of the statute’s purported disparate treatment of prosecutors and criminal defense attorneys; and (4) the district court did not abuse its discretion in denying Defendant’s motion in limine to exclude expert testimony related to the Wyoming Toolkit. View "State v. Roberts" on Justia Law

After a jury trial, Defendant was convicted of murder, aggravated robbery, and unlawful distribution of a controlled substance. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion when it admitted Y-STR DNA evidence linking Defendant to the murder weapon; (2) the trial court did not err when it refused to admit the entire transcript or video of Defendant’s second police interview after a State witness testified to portions of the interview at trial; (3) defense counsel did not render ineffective assistance in his cross-examination of one of the detectives who conducted the second interview; (4) the trial court did not err when it admitted an officer’s testimony about the frequency of drug-related crimes; (5) the State did not engage in prosecutorial misconduct during closing argument; (6) the evidence was sufficient to sustain convictions for murder and aggravated robbery; and (7) Defendant failed to demonstrate cumulative error that undermined confidence in the verdict. View "State v. Jones" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury returned a sentence of life without parole. Defendant appealed and also filed motions to remand under Utah R. App. P. 23 and 23B. The Supreme Court (1) denied Defendant’s motion to supplement the record under Rule 23 as an improper means to supplement the record for appeal; and (2) granted Defendant’s Rule 23 B motion on several of his claims and remanded this case to the trial court on those claims, holding that remand was necessary to supplement the record regarding Defendant’s claims of conflict of interest, failure to investigate a witness, and failure to introduce evidence of a burglary of the victim’s home. View "State v. Griffin" on Justia Law

After a jury trial, Defendant was convicted of murder with an enhancement for criminal street gang activity, obstruction of justice, and possession or use of a dangerous weapon by a restricted person. The Supreme Court affirmed, holding that the trial court (1) correctly denied Defendant’s motion for directed verdict on the murder and obstruction-of-justice charges; (2) did not abuse its discretion by permitting the State to present gang-related evidence during the guilt phase of the trial; and (3) did not abuse its discretion by dismissing as untimely Defendant’s constitutional challenge to the gang-enhancement statute. View "State v. Gonzalez" on Justia Law