Justia Utah Supreme Court Opinion Summaries

Defendant pled no contest to patronizing a prostitute in Layton City after negotiating a plea in abeyance agreement. The agreement contained the condition that Defendant would commit “no violations of law.” Defendant was subsequently charged in Sunset City with sexual solicitation. The action was dismissed after Defendant entered into a diversion agreement with Sunset City. Thereafter, the Second District Court held a hearing to determine whether Defendant violated the plea in abeyance agreement condition requiring that he commit no further violations of law. The district court concluded that the “no violations of law” condition in the plea abeyance agreement required a conviction, and entering into the diversion agreement did not constitute a conviction. The Court of Appeals reversed, concluding that the prosecution may show that the defendant failed to comply with the condition through evidence of misconduct other than a conviction. The Supreme Court affirmed, holding (1) the prosecution need not provide proof of a conviction to establish that a defendant failed to comply with a plea in abeyance condition prohibiting further violations of law; and (2) the prosecution must prove by a preponderance of the evidence that a defendant failed to comply with a condition in a plea in abeyance agreement. View "Layton City v. Stevenson" on Justia Law

In 2009, Petitioner entered a plea in abeyance to a charge of lewdness that ultimately culminated in a conviction. In 2010, Petitioner was convicted of a second act of lewdness. In 2011 and 2012, Petitioner was subject to further lewdness charges. Petitioner was charged with felonies in light of his prior convictions. At this point, Petitioner sought to challenge his 2010 conviction, alleging that he had been deprived of his right to appeal the 2010 decision under the standards set forth in Utah R. App. P. 4(f) and Manning v. State. The justice court denied Petitioner’s motion. On de novo appeal to the district court, the court determined that Petitioner had waived the right to assert the denial of his right to appeal under Manning by waiting too long to assert that claim. Petitioner sought extraordinary relief challenging the dismissal of his appeal. The Supreme Court granted the petition, holding (1) Rule 4(f) governed Petitioner’s motion to reinstate his appeal from justice court to district court in a manner foreclosing the district court’s waiver analysis; (2) the district court retained jurisdiction to consider Petitioner’s motion; and (3) the Post-Conviction Remedies Act’s exclusive remedy provision was inapplicable. View "Ralphs v. District Court" on Justia Law

Defendant pled guilty to one count of attempted aggravated sexual abuse of a child. The district court neither conducted a preliminary hearing nor obtained a waiver of Defendant’s right to a preliminary hearing. After Defendant was sentenced he appealed, arguing that the district court lacked subject matter jurisdiction to enter his guilty plea because he was neither afforded the right to a preliminary hearing nor did he expressly waive his right to a preliminary hearing. The Supreme Court affirmed, holding that, as set forth in State v. Smith, which the Court also issued today, a district court’s failure to conduct a preliminary hearing, obtain a waiver of the right to a preliminary hearing, or issue a bindover order is a nonjurisdictional defect. View "State v. Young" on Justia Law

Under the terms of a plea agreement Defendant agreed to plead guilty to a second-degree felony. Defendant and his wife appeared in court for their joint preliminary hearing, but a preliminary hearing never occurred. Eventually, Defendant pleaded guilty to second-degree felony possession or use of a controlled substance in a drug-free zone. After Defendant was sentenced he appealed, arguing that because he was never bound over following either a preliminary hearing or an express waiver of the right to a preliminary hearing, the district court never obtained subject matter jurisdiction over the case. The court of appeals agreed with Defendant, determining that the guilty plea was void. The Supreme Court reversed, holding (1) it is error for a district court to accept a guilty plea without holding a preliminary hearing or obtaining an express waiver from the defendant of the right to a preliminary hearing, but (2) such an error does not deprive the court of subject matter jurisdiction. View "State v. Smith" on Justia Law

In 2002, Appellant, a Mexican native and a lawful permanent resident of the United States, pleaded guilty to felony theft. Eight years later, deportation proceedings were initiated against Appellant, in part due to Appellant’s 2002 felony theft conviction. Appellant filed a petition asking the district court to vacate his 2002 plea under the Utah Post-Conviction Remedies Act (PCRA) or, alternatively, through a writ of coram nobis. In his petition, Appellant claimed that his counsel was ineffective during the plea process by failing to disclose the possible immigration consequences related to his plea. The district court dismissed Appellant’s petition and writ of coram nobis, concluding (1) Appellant’s petition was time barred by the PCRA, and (2) Appellant was not deprived of effective assistance of counsel, as Appellant knew or should have known that there were potential immigration consequences related to his plea. The Supreme Court affirmed, holding (1) Appellant failed to preserve his argument that his attorney affirmatively misrepresented the immigration consequences of his plea; and (2) the district court did not err in denying Appellant’s petition for a writ of coram nobis, as Appellant had a remedy available to him through the PCRA. View "Oseguera v. State" on Justia Law

After law enforcement officers discovered child pornography on Defendant’s computer, they applied for and obtained a federal search warrant to search the computer. Defendant subsequently pled guilty to five counts of voyeurism. Defendant appealed, arguing that the district court erred in denying his motion to suppress because the warrant was not sufficiently particular and lack probable cause and because his statements to the officers violated his Fifth Amendment right against self-incrimination. The Supreme Court affirmed, holding (1) the warrant was sufficiently particular and supported by probable cause; and (2) Defendant was not in custody at the time he made the statements to the law enforcement officers so the officers’ failure to read him his Miranda rights did not violate the Fifth Amendment. View "State v. Fuller" on Justia Law

Petitioner was convicted of aggravated murder and sentenced to death. The Supreme Court affirmed the conviction and sentence. Petitioner subsequently filed a petition for postconviction relief, alleging that his counsel provided ineffective assistance at trial. The postconviction court granted summary judgment in favor of the State. Petitioner filed a notice of appeal in his postconviction proceedings and then filed a Utah R. Civ. P. 60(b) motion to set aside the postconviction court’s final judgment. The postconviction court denied the motion. The Supreme Court consolidated the appeals and affirmed the postconviction court’s grant of summary judgment and denial of Rule 60(b) relief, holding (1) Petitioner failed to raise a genuine issue of material fact for each of his ineffective assistance of counsel claims; and (2) the postconviction court did not abuse its discretion when it denied Petitioner’s motion for relief from judgment pursuant to Rule 60(b). View "Honie v. State" on Justia Law

Defendant pled guilty to unlawful sexual conduct with a minor. Defendant later moved to withdraw his guilty plea based upon ineffective assistance of counsel and a violation of Utah R. Crim. P. 11, arguing that his plea was not knowing or voluntary because neither his defense counsel nor the trial court informed him that his guilty plea carried with it the requirement that Defendant register on the state’s sex offender registry. The district court denied Defendant’s motion to withdraw, concluding that neither defense counsel nor the district court had an obligation to inform him of the registration requirement because the registration requirement was a collateral consequence of the guilty plea. The Supreme Court affirmed, holding that the requirement to register as a sex offender is properly classified as a collateral consequence of a defendant’s guilty plea, and therefore, neither defense counsel nor the trial court in this case was constitutionally obligated to inform Defendant of the registration requirement before his guilty plea was accepted as knowing and voluntary. View "State v. Trotter" on Justia Law

After a jury trial, Frank and Joan Steed, husband and wife, were each convicted of three counts of failure to file a proper tax return and one count of engaging in a pattern of unlawful activity. The failure-to-file statute requires proof that a defendant failed to file with one of three specific intents. The Steeds moved to arrest the judgment largely on the same grounds upon which they relied in a previously denied motion to dismiss. Specifically, the Steeds contended that the State failed to provide sufficient evidence of two of the three specific intent alternatives. Ultimately, the trial court submitted only the two contested intent alternatives to the jury and excluded the remaining intent alternative. The Supreme Court reversed the Steeds’ convictions, holding (1) the State presented insufficient evidence of the two contested intent alternatives; (2) because the court excluded the single supported intent alternative and submitted the two unsupported intent alternatives to the jury, there was insufficient evidence to support the verdicts; and (3) because the pattern counts were contingent on the failure-to-file convictions, the pattern counts, along with the failure-to-file convictions, must be reversed. View "State v. Steed" on Justia Law

After a jury trial, Appellant was convicted of murder and child abuse for the death of her two-year-old son, Alex. Appellant appealed her convictions on several grounds. The Supreme Court affirmed, holding (1) a preponderance of the evidence is required to admit evidence of prior bad acts, and the trial court did not abuse its discretion in admitting evidence of prior child abuse under Utah R. Evid. 404(b); (2) Appellant’s defense counsel was not ineffective for, among other things, deciding not to introduce expert testimony regarding Battered Woman’s Syndrome because the trial strategy he selected was objectively reasonable; and (3) there was no cumulative error. View "State v. Lucero" on Justia Law