Justia Utah Supreme Court Opinion Summaries

In the case before the Supreme Court of the State of Utah, the defendant, Alfonso Valdez, was arrested and charged with kidnapping and assaulting his ex-girlfriend. During the arrest, officers seized Valdez’s cell phone. The police later obtained a search warrant for the phone, but were unable to access the contents as they could not decipher Valdez's passcode. When asked to provide his passcode, Valdez refused. At trial, the State elicited testimony about Valdez's refusal to provide his passcode and argued that this refusal undermined one of his defenses. Valdez was subsequently convicted.On appeal, the court of appeals reversed the conviction, agreeing with Valdez that he had a Fifth Amendment right to refuse to provide his passcode, and that the State violated this right by using his refusal against him at trial.The State petitioned the Supreme Court of the State of Utah for certiorari, arguing that providing a passcode is not a testimonial communication, that the “foregone conclusion” exception applies in this case, and that the prosecutor's comments were permissible as a fair response to an issue that Valdez initiated.The Supreme Court disagreed with the State on all counts. The court held that verbally providing a cell phone passcode is a testimonial communication under the Fifth Amendment and that the "foregone conclusion" exception, which arises in cases where an “act of production” implicitly communicates information, does not apply. The court also rejected the State's "fair response" argument, concluding that the State had elicited the testimony about Valdez's refusal to provide his passcode before Valdez had raised any issue involving the contents of his phone. Consequently, the court affirmed the decision of the court of appeals. View "State v. Valdez" on Justia Law

In this case, the defendant, Floyd Corry Robinson, argued that his sentence was unconstitutional because his counsel was ineffective and because the State suppressed evidence. Robinson brought his motion under Rule 22(e) of the Utah Rules of Criminal Procedure, which allows for correction of a sentence under certain circumstances. The Supreme Court of the State of Utah found that Robinson's claims did not fall under any of the categories listed in Rule 22(e) that would allow for a sentence correction. The court ruled that the district court correctly denied Robinson's motion, as his claims were not cognizable under Rule 22(e). The Supreme Court also rejected Robinson's argument that his filing should have been treated as a petition for post-conviction relief, not a Rule 22(e) motion. The court reasoned that Robinson's filing clearly invoked Rule 22(e) and did not suggest an intent to seek a different form of relief. The court therefore affirmed the district court's denial of Robinson's motion. View "State v. Robinson" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion filed under Utah R. Civ. P. 60(b)(6), which allows a court to grant relief from a judgment under certain circumstances, holding that Defendant's challenge to his conviction could have been brought in a petition for post-conviction relief.Defendant pled guilty to two counts of attempted aggravated sexual abuse of a child. Defendant did not file a direct appeal and did not challenge his conviction under Utah's Post-Conviction Remedies Act (PCRA) but later filed a motion under Rule 60(b)(6) alleging ineffective assistance of counsel. The district court denied the motion, ruling that Rule 60(b)(6) was not the appropriate vehicle for Defendant to bring his claim. The Supreme Court affirmed, holding that the PCRA applied to Defendant's request to set aside his conviction based on his trial counsel's alleged conflict of interest. View "State v. Ogden" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of rape, one count of aggravated assault, and two counts of domestic violence in the presence of a child, holding that Defendant was not entitled to relief on his multiple claims of error.Specifically, the Supreme Court held (1) the district court did not abuse its discretion in not withholding from jury deliberations a video exhibit of Defendant's police interview; (2) Defendant failed to show that he was prejudiced by the alleged deficient performance of his trial counsel; and (3) the district court did not err in denying Defendant's motions for a mistrial and a new trial arising out of a child witness's breakdown on the witness stand. View "State v. Centeno" on Justia Law

The Supreme Court affirmed the judgment of the district court rejecting the State's interpretation of Utah Const. art. I, section 8(1) to mandate that a judge deny bail to a defendant charged with a felony if that defendant is already serving probation on a felony conviction, holding that there was no error.Defendant was serving probation when he was charged with felony crimes in both Salt Lake and Davis counties. At the Davis County bail hearing the State argued that Utah Const. art. I, section 8(1) mandates that a judge deny bail to a defendant charged with a felony if that defendant is already serving probation on a felony conviction. The district court disagreed with the State's interpretation and set bail. The Supreme Court affirmed, holding that the district court correctly determined that it could grant Defendant bail. View "State v. Barnett" on Justia Law

In this appeal from the denial of a post-conviction determination of factual innocence pursuant to the Post-Conviction Remedies Act the Supreme Court remanded the case to the district court, holding that further proceedings were required in accordance with the legal standards set forth in this opinion.After a jury trial, Defendant was convicted of two counts of aggravated sexual abuse of a child for allegedly abusing her son, Kevin. Approximately one decade later Defendant recanted his statements. Based on the recantation, Defendant filed his petition for a post-conviction determination of factual innocence. The district court denied the petition after holding an evidentiary hearing. The Supreme Court remanded the case, holding (1) Kevin's recantation, if believable, was sufficient to prove Defendant's factual innocence by clear and convincing evidence; (2) the district court erred in denying the petition without weighing all of the relevant evidence, assessing credibility, or making an ultimate finding on the recantation's veracity; and (3) to the extent the district court made an implicit credibility determination, it was based on a clearly erroneous factual finding that certain facts were disputed. View "Ashby v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of aggravated arson, holding that the court of appeals did not err in concluding that Defendant's counsel did not render ineffective assistance.On appeal, Defendant argued that his counsel provided ineffective assistance by failing to move for a directed verdict and by failing to object to the testimony of an expert who opined that the structure Defendant had set fire to was habitable. A divided court of appeals affirmed. The Supreme Court affirmed, holding (1) reasonable counsel could have decided to forgot a motion for directed verdict; and (2) the court of appeals correctly concluded that Defendant was not deprived of the Sixth Amendment guarantees. View "State v. Carter" on Justia Law

The Supreme Court affirmed the judgment of the trial court in this interlocutory appeal of the denial of Defendant's motion to suppress calls made by Defendant on the Salt Lake County Jail's telephones and recorded by the jail, holding that Defendant impliedly consented to the conditions the jail had placed on the use of its phones.Defendant was charged with kidnapping and assaulting his wife and made hundreds of calls to his wife from the jail. The State moved to admit recording of several of those phone calls and filed new charges based on the recordings. Defendant filed a motion to suppress the recordings in both cases. The Supreme Court denied the motions, concluding that Defendant impliedly consented to the interception of the phone calls and that the calls were exempt under the law enforcement exception to Utah's Interception of Communications Act, Utah Code 77-23a-1 to -16. The Supreme Court affirmed, holding that Defendant impliedly consented to the jail's recording of his phone calls, and therefore, the interception of Defendant's calls was authorized under the Interception Act's consent exception. View "State v. Wood" on Justia Law

In this ongoing sexual abuse of a child case the Supreme Court denied Defendant's motion filed under rule 4-202.04 of the Utah Code of Judicial Administration seeking access to F.L.'s therapy records that the trial court sealed after its in camera review, holding that the balance of interests weighed in favor of keeping F.L.'s therapy records sealed during appellate review.Defendant was charged with four counts of sexual abuse of a child, F.L. In preparing his defense, Defendant requested that the trial court order in camera review of the records of multiple entities that had provided mental health services to F.L. and that the record contained references "to this incidents alleged to have occurred" in his case. The court authorized in camera review of the records, provided Defendant with relevant portions of the records, and then sealed them. After Defendant was convicted on one count, he appealed. The court of appeals unsealed the therapy records, and Defendant used them to prepare his appellate brief. F.L. requested that the court of appeals re-seal her records, which the court did. The Supreme Court denied Defendant's request to access the records, holding that the interests favoring the records' closure outweighed those favoring Defendant's access. View "State v. Chadwick" on Justia Law

The Supreme Court affirmed Defendant's convictions for sexually assaulting six women, holding that the doctrine of chances precedent should be abandoned in favor of a plain-test reading of rules 402, 403 and 404(b) of the Utah Rules of Evidence.On appeal, Defendant argued that under rules 404(b) and 403 and the doctrine of chances, the district court erred in allowing the admission of other acts evidence to show that he sexually assaulted a particular victim. The Supreme Court disagreed and affirmed, holding (1) in an analysis of whether the district court erred in admitting the other-acts evidence under the rules of evidence, without reference to the doctrine of chances, there was no error in the district court's other-acts evidence determination; (2) most of Defendant's hearsay claims were properly admitted consistent with exemptions to the hearsay rule, and any errors in admitting statements that should have been excluded as hearsay were harmless; and (3) Defendant's claims of ineffective assistance of counsel were unavailing. View "State v. Green" on Justia Law