Justia Utah Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of sexual battery, a misdemeanor. Before trial, the district court ruled that evidence of other sexual misconduct allegations against Defendant was inadmissible. However, during redirect examination of an investigating detective, the prosecutor elicited testimony about other allegations of sexual misconduct against Defendant, which was classified as Utah R. Civ. P. 404(b) evidence. A panel majority of the court of appeals reversed and remanded for a new trial after refusing to apply the presumption of regularity in favor of the State, holding that the district court plainly erred and counsel rendered ineffective assistance in allowing the Rule 404(b) evidence. The Supreme Court reversed without addressing the State’s argument that a gap in the record of a criminal trial should always be interpreted in favor of the State, holding that Defendant’s trial counsel was not ineffective in referencing and admitting the Rule 404(b) evidence, and the district court did not commit plain error in allowing the evidence to be presented. Remanded. View "State v. Bedell" on Justia Law

Defendant confessed to helping Glenn Griffin commit murder. The State charged both Griffin and Defendant with the crime. The State prosecuted Griffin first and, concerned that Defendant would invoke his privilege against self incrimination and refuse to testify, offered Defendant use immunity. The district judge subsequently issued an order compelling Defendant to testify, but Defendant refused. Thereafter, the State charged Defendant with three counts of obstruction of justice. After a hearing, the magistrate judge refused to bind Defendant over for trial and dismissed the obstruction of justice charges. The court of appeals affirmed, finding that State had failed to present sufficient evidence of intent to obstruct. The Supreme Court reversed, holding that the evidence was sufficient to bind Defendant over for trial for obstruction of justice. Remanded.View "State v. Maughan" on Justia Law

After a jury trial, Defendant was convicted of misdemeanor sexual battery. The court of appeals reversed the conviction and remanded for a new trial, concluding that the district court plainly erred and Defendant's trial counsel was ineffective in allowing the investigative detective's testimony on redirect examination about other allegations of sexual misconduct against him. The Supreme Court reversed, holding that trial counsel was not ineffective in referencing and admitting the Utah R. Evid. 404(b) evidence, and the district court did not commit plain error in allowing the evidence to be presented. In so holding, the Court did not address the State's argument that a gap in the record of a criminal trial should always be interpreted in favor of the State. View "State v. Bedell" on Justia Law

Defendant was arrested and removed from a home he owned with his wife. Soon afterwards, Defendant's wife obtained a restraining order that prohibited Defendant from going to the family home for 150 days. About three weeks after the restraining order expired, Defendant entered the home and brandished a rifle. Defendant was subsequently charged with aggravated burglary, aggravated assault, and commission of domestic violence in the presence of a child. A magistrate found Defendant could not be bound over on the aggravated burglary charge because there was insufficient evidence that Defendant had relinquished his possessory interest in the family home to render his entry unlawful under Utah's burglary statute. The Supreme Court affirmed, holding (1) an estranged spouse may implicitly relinquish his or her possessory rights to the marital home by voluntarily establishing a separate residence; but (2) in this case, the State did not produce sufficient evidence of voluntary relinquishment. Remanded. View "State v. Machan" on Justia Law

After a jury trial, Appellant was convicted of two counts of aggravated sexual assault and one count of robbery for the 1996 attack and sexual assault of a twenty-three-year-old woman. On appeal, Appellant contended that the statute of limitations had run before the State commenced its prosecution of Appellant and, alternatively, that his right to a speedy trial was violated. The Supreme Court affirmed Appellant's convictions, holding that the State commenced Appellant's prosecution within the applicable statute of limitations and that Appellant's right to a speedy trial was not violated, where, while this case involved an extraordinary delay, the delay was not the fault of the State and Appellant was not prejudiced. View "State v. Young" on Justia Law

After a jury trial, Appellant was convicted of two counts of aggravated sexual abuse of a child and one count of dealing in material harmful to a minor. Defendant appealed, arguing, among other things, that the prosecutor prejudiced the jury by making several improper comments during closing arguments. The Supreme Court vacated Defendant's convictions and remanded for a new trial on all counts, holding (1) Defendant failed to preserve his arguments based on prosecutorial misconduct for appeal; but (2) nevertheless, defense counsel's failure to object to the prosecutor's conduct at trial constituted ineffective assistance of counsel. View "State v. Larrabee" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated murder and two counts of attempted murder. Defendant was sentenced to life without parole for each aggravated murder conviction and three years to life for each attempted murder conviction. The Supreme Court affirmed, holding (1) although the district court erred when it limited and excluded the testimony of the defense's expert witnesses, these errors were harmless; (2) the combined result of these errors did not undermine the Court's confidence in the verdict; and (3) Utah Code 76-3-207.7, which provides the sentencing scheme for first degree felony aggravated murder, is constitutional on its face and was constitutionally applied to Defendant. View "State v. Perea" on Justia Law

After a jury trial, Defendant, who was temporarily staying in the spare bedroom of the victim's father's house, was convicted of aggravated sexual abuse of a child. Defendant's conviction was based on the holding that he occupied a "position of special trust" in relation to the victim under Utah Code 76-5-404.1(4)(h). The district court and court of appeals both held Defendant was an "adult cohabitant" of a parent of the child, which was one of several positions specifically referenced in section 76-5-404.1(4)(h). The Supreme Court vacated Defendant's conviction and remanded, holding (1) the fact that a defendant occupies one of the positions listed in section 76-5-404.1(4)(h) is insufficient, standing alone, to establish the crime of aggravated sexual abuse of a child; (2) for the State to establish aggravated sexual abuse of a child under subsection 4(h), it must prove both that the defendant occupied a "position of authority" over the victim and that the position gave the defendant the ability to "exercise undue influence" over the victim; and (3) because the lower courts did not require the State to establish both elements, Defendant's conviction must be vacated.View "State v. Watkins" on Justia Law

After a jury trial, Defendant was convicted of aggravated murder, aggravated robbery, and aggravated assault and sentenced to life without parole on the murder conviction. The Supreme Court affirmed, holding (1) Defendant failed to show that the prosecution's decision to charge him with aggravated murder and the district court's denial of his motion to amend the charge to murder violated his constitutional rights; (2) the aggravated murder statute is constitutional; and (3) the admission of victim impact testimony at Defendant's sentencing hearing did not violate constitutional prohibitions against cruel and unusual punishments, and therefore, defense counsel's failure to object to the testimony did not constitute ineffective assistance of counsel. View "State v. Mateos-Martinez" on Justia Law

In 1993, Jed Gressman was convicted of aggravated sexual assault and sentenced to a term of five years to life. In 1996, Gressman moved to dismiss the charges against him based on newly-discovered evidence. The district court vacated Gressman's conviction based on the newly-discovered evidence. In 2009, Gressman filed suit under the Post-Conviction Remedies Act (PCRA) seeking to obtain his factual innocence and obtain financial assistance. Gressman died during pendency of the suit, so counsel moved to substitute Gressman's widow. The district court substituted Gressman's widow, granted Gressman's widow's motion for summary judgment, and awarded Gressman's widow PCRA assistance payments, including prejudgment interest. The State appealed. The Supreme Court reversed for further proceedings, holding (1) Gressman's PCRA claims survived his death, and thus, the district court properly substituted Gressman's widow as the plaintiff in this suit; (2) the district court erred when it found that the vacatur of Gressman's conviction conclusively established his factual innocence as defined by the PCRA; and (3) the district court erred in awarding prejudgment interest. View "Gressman v. State" on Justia Law