Justia Utah Supreme Court Opinion Summaries

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

On May 8, 2012, legislative amendments to the Indigent Defense Act (IDA) became effective. The amendments override the Supreme Court’s construction of the prior version of the IDA by precluding an indigent defendant in a criminal action from retaining private counsel while requesting public defense resources from the government. In two criminal cases against Defendant, Defendant, who was represented by private counsel, filed requests for government-funded defense resources. Defendant’s motions for government-funded defense resources were filed on May 8, 2012 and November 29, 2012. The district court judges denied Defendant’s requests. The Supreme court affirmed, holding (1) the conduct being regulated by the IDA is the exercise of a mature right to indigent defense resources, and the law in effect at the time that Defendant exercised that mature right was the amended version of the IDA; and (2) Defendant’s constitutional and statutory challenges to the application of the IDA amendments to her case were without merit. View "State v. Earl" on Justia Law

On May 8, 2012, legislative amendments to the Indigent Defense Act (IDA) became effective. The amendments override the Supreme Court’s construction of the prior version of the IDA by precluding an indigent defendant in a criminal action from retaining private counsel while requesting public defense resources from the government. In the instant criminal case, Defendant was charged with object rape, a first-degree felony. Defendant retained private counsel and, in April 2012, filed a motion requesting the provision of government-funded defense resources. The district court granted the motion, concluding that Defendant was entitled to the pre-amendment of the IDA applied because Defendant was entitled to the version of the IDA in effect at the time he filed his motion requesting defense resources. The Supreme Court affirmed, holding that the pre-amendment version of the IDA should apply in this case because the conduct being regulated by the IDA is the exercise of a mature right to indigent defense resources, and the law in effect at the time that Defendant exercised that mature right was the unamended version of the IDA. View "State v. Perez" on Justia Law

On May 8, 2012, legislative amendments to the Indigent Defense Act (IDA) became effective. The amendments override the Supreme Court’s construction of the prior version of the IDA by precluding an indigent defendant in a criminal action from retaining private counsel while requesting public defense resources from the government. In the instant criminal case, Defendant was charged with murder. Defendant retained private counsel, and, on May 3, 2012, filed a motion asking the district court to order the provision of government-funded defense resources. The district court denied the motion, concluding that the IDA regulated a matter of procedure, and thus, the amended statute applied retroactively to cases pending on its effective date. The Supreme Court reversed, holding that on the date Defendant filed his motion requesting the provision of defense resources, his right to request those resources was fully vested. Therefore, Defendant was entitled to the benefit of the law in place on May 3, 2012, and subsequent changes to the law could not be applied retroactively to undermine his motion. Remanded. View "State v. Folsom" on Justia Law

On May 8, 2012, legislative amendments to the Indigent Defense Act (IDA) became effective. The amendments override the Supreme Court’s construction of the prior version of the IDA by precluding an indigent defendant in a criminal action from retaining private counsel while requesting public defense resources from the government. In the instant criminal case, Defendant was charged with four first-degree felonies. About one month after the 2012 amendments to the IDA became effective, Defendant, who was represented by private counsel, filed a motion requesting government-funded defense resources under the pre-amendment version of the IDA. The district court granted the motion, determining that the earlier version of the statute applied because the IDA amendments were substantive and because the pre-amendment version was the one in effect at the time of Defendant’s alleged offenses. The Supreme Court reversed, holding (1) the 2012 version of the IDA should apply in this case because the conduct being regulated by the IDA is the exercise of a mature right to indigent defense resources, and the law in effect at the time that Defendant exercised that mature right was the amended version of the IDA; and (2) the 2012 amendments, as applied to this case, are constitutional. View "State v. Steinly" on Justia Law