Justia Utah Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of failure to respond to an officer’s signal to stop, a third degree felony under Utah Code 41-6a-210. Defendant appealed, arguing that the trial court erred when it failed to instruct the jury on the mental state required for the conviction. The court of appeals agreed and reversed. The court of appeals did not, however, provide guidance on remand regarding a correct jury instruction. The Supreme Court (1) affirmed the court of appeals’ reversal of Defendant’s conviction because the instruction given to the jury did not specify the essential mens rea elements of the failure-to-respond charge; and (2) held that the court of appeals did not err in asking the trial court to determine, in the first instance, the proper mens rea instruction. The Court then exercised its discretion to provide such guidance. View "State v. Bird" on Justia Law

At issue in this case was the applicability of the “attenuation” exception to the exclusionary rule to a fact pattern involving an unlawful detention leading to the discovery of an arrest warrant followed by a search incident to arrest. Defendant in this case entered a conditional plea to drug-related charges, reserving the right to appeal the denial of his motions to suppress and reconsider. The court of appeals affirmed under the attenuation exception to the exclusionary rule. After noting that the lower courts are in “disarray” in their application of the attenuation doctrine to the outstanding warrant scenario and the lack of direction from the U.S. Supreme Court on the matter, the Supreme Court concluded (1) the attenuation exception is limited to cases involving intervening acts of a defendant’s free will, as in a confession or consent to search; and (2) because this case involved no independent act of a defendant’s free will, the attenuation doctrine was not implicated, and Defendant was entitled to suppression of the evidence secured in the search incident to his arrest. View "State v. Strieff" on Justia Law

After a jury trial, Defendant was found guilty of one count of murder and two counts of aggravated robbery. Upon sentencing Defendant, the trial court failed to comply with Utah R. Crim. P. 22(c)(1) by not informing Defendant of his right to appeal and of the thirty-day deadline for filing a notice of appeal. Over two years later, Defendant filed a motion seeking reinstatement of his right to appeal. The trial court denied the motion. The court of appeals reversed, concluding that because neither the trial court nor defense counsel informed Defendant of the thirty-day deadline, Defendant had a valid claim for reinstatement of the right to appeal. The Supreme Court reversed, holding that claims for reinstatement of the right to appeal are subject to harmless error review, and the court of appeals in this case erred by declining to apply harmless error analysis. Remanded. View "State v. Collins" on Justia Law

Defendant was convicted of five securities law violations and one count of maintaining a pattern of unlawful activity related to an investment scheme. The court of appeals reversed Defendant’s securities law convictions, concluding that her counsel rendered ineffective assistance by stipulating to a jury instruction that the court concluded impermissibly shifted the burden to Defendant and relieved the State of its burden to prove each element of an offense beyond a reasonable doubt. The Supreme Court reversed, holding that the jury instruction at issue was an accurate statement of Utah law and not an evidentiary presumption unlawfully shifting the burden of proof to the defense. Remanded. View "State v. Kelson" on Justia Law

Utah Code 76-10-503 criminalizes possession of a “dangerous weapon” by a restricted person. Defendant was convicted under section 76-10-503 for having a pocketknife among his personal belongings, which he carried with him in a shopping cart. On appeal, Defendant argued that his pocketknife did not qualify as a dangerous weapon under the statutory definition of "dangerous weapon" in subsection 76-10-501(6) because the statute permitted consideration only of a knife’s actual use, not its intended use. The court of appeals affirmed, holding (1) an object’s intended use may be considered in determining whether an object is a dangerous weapon; and (2) the evidence was sufficient to establish that Defendant’s knife was a dangerous weapon. The Supreme Court reversed the court of appeals and vacated Defendant’s conviction, holding (1) subsection 76-10-501(6) permits consideration only of how the object was actually used; and (2) therefore, the evidence presented at trial was insufficient to establish that the knife in Defendant’s shopping cart was a dangerous weapon as defined by statute. View "Salt Lake City v. Miles" on Justia Law

Defendant was charged with several crimes involving sexual conduct with a minor. L.N., the alleged victim on each charge, sought to intervene by filing a notice of a claim for restitution. The State filed a parallel request for restitution, seeking travel costs and lost wages incurred by L.N. and her mother to attend hearings. The district court granted Defendant’s motion to strike, holding (1) crime victims are not parties to criminal proceedings and thus lack standing to file requests for restitution; and (2) the travel expenses and lost wages incurred by L.N. and her mother fell beyond the scope of recoverable restitution. The Supreme Court affirmed, holding that a crime victim has standing to file a request for restitution, but the district court’s error in denying L.N.’s filing was harmless, as restitution is allowed only for the pecuniary damages that a victim could recover in a civil action arising out of the defendant’s criminal conduct. Thus, the restitution at issue in this case was not properly compensable. View "State v. Brown" on Justia Law

Defendant was charged with one count of aggravated sexual assault and two counts of domestic violence in the presence of a minor arising out of his attack on his wife in the presence of the parties’ four-year-old daughter. During voir dire, defense counsel used all five of his peremptory challenges on female members of the venire. The prosecution objected, and because Defendant failed to give nondiscriminatory explanations for two of the strikes, the trial court reinstated those two jurors. The court, however, did not restore the two peremptory challenges Defendant used to strike the jurors. The court of appeals affirmed, concluding that Defendant had not shown he was actually prejudiced by his counsel’s allegedly deficient performance or by the trial court’s alleged errors. the Supreme Court affirmed, holding (1) Defendant failed to show that any prejudice arose from any arguable deficiency in his counsel’s performance or that there was a basis for a presumption of prejudice; and (2) Defendant failed to establish the elements of plain error in regard to the trial court’s decision to reinstate the two jurors and its failure to sua sponte restore the peremptory challenges used to strike them. View "State v. Sessions" on Justia Law

Nearly twenty years ago Appellant was convicted of first degree murder and sentenced to death. After Appellant’s conviction and sentence were affirmed on direct appeal, Appellant unsuccessfully sought post-conviction relief. The Supreme Court reversed the dismissal of Appellant’s post-conviction petition and allowed him to amend his petition. Ultimately, Appellant filed a fifth amended petition for relief under the Utah Post-Conviction Remedies Act (PCRA), which the post-conviction court (PCC) denied. Appellant appealed the denial of his fifth amended petition, raising numerous claims. The Supreme Court affirmed, holding (1) Appellant’s challenge to the constitutionality of the PCRA failed because he did not establish he had a constitutional right to funded post-conviction counsel, and the PCC did not abuse its discretion in denying Appellant further PCRA funding; (2) the PCC did not err in rejecting several of Appellant’s post-conviction motions; and (3) Appellant did not receive ineffective assistance of counsel during the guilt-phase, penalty-phase, or appellate proceedings. View "Menzies v. State" on Justia Law

Petitioner was convicted of aggravated kidnapping, aggravated assault, and cruelty to an animal. Petitioner was sentenced to life without the possibility of parole (LWOP) for the aggravated kidnapping conviction. Petitioner appealed, arguing that the district court abused its discretion in imposing a sentence of LWOP for his aggravated kidnapping conviction because the court failed to properly consider whether the interests of justice warranted a lesser sentence as allowed for in Utah’s aggravated kidnapping statute. The court of appeals upheld Petitioner’s LWOP sentence. The Supreme Court vacated Petitioner’s sentence of LWOP, holding that the district court erred when it considered only those aggravating and mitigating circumstances recognized by the Sentencing Commission instead of broadly considering the interests of justice required by the aggravated kidnapping statute. Remanded. View "State v. Lebeau" on Justia Law

After a jury trial, Defendant was convicted of five securities law violations and one count of maintaining a pattern of unlawful activity related to an investment scheme. The court of appeals reversed Defendant’s five securities law convictions, concluding that Defendant’s counsel rendered ineffective assistance by failing to object to a jury instruction stating that a “note is presumed to be a security” because that instruction impermissibly relieved the prosecution of its burden to prove each element of the securities crimes with which Defendant was charged. The Supreme Court reversed and reinstated Defendant’s five securities law convictions, holding that the instruction at issue was an accurate statement of law and not a burden-shifting evidentiary presumption. View "State v. Kelson" on Justia Law