Justia Utah Supreme Court Opinion Summaries

Judge Judith Atherton presided over a criminal proceeding involving an indigent defendant in which Atherton ordered the Salt Lake Legal Defender Association (LDA) to provide funding for the defendant's expert. LDA was not given notice of the hearing on the defendant's motion requesting funding for his expert witness and was not present at the hearing. LDA filed a petition for extraordinary relief. The Supreme Court granted the petition and vacated Atherton's order, holding that Atherton violated LDA's right to due process by ordering LDA to provide funding for the defendant's expert witness without giving it notice or an opportunity to be heard. Remanded. View "Salt Lake Legal Defender Ass'n v. Third District Court (Atherton) " on Justia Law

Chanzy Walker was involved in an accident that killed one person. The detectives investigating the incident obtained a warrant from a magistrate judge to draw and test Walker's blood. A blood sample from Walker revealed the presence of methamphetamine and amphetamine. After the State charged Walker with several offenses, Walker filed a motion to suppress the results of the blood test. At a pretrial hearing, The district court concluded that the warrant lacked probable cause. Despite this conclusion, the district court denied the motion to suppress based on its determination that the good faith exception to the exclusionary rule applied in this case. Walker later entered a conditional plea to causing the death of another by operating a motor vehicle in a negligent matter with a controlled substance in the body and possessing a controlled substance. The Supreme Court affirmed the district court's denial of Walker's motion to suppress, holding that the magistrate had a substantial basis to believe that evidence of illegal conduct would be found in Walker's blood and, therefore, the warrant was supported by probable cause. View "State v. Walker" on Justia Law

Douglas Lovell pleaded guilty to aggravated murder. Lovell subsequently moved to withdraw his plea. The district court initially held that Lovell's motion was untimely, but the Supreme Court reversed and remanded for consideration of the merits of Lovell's motion. In district court, Lovell argued he had good cause to withdraw his plea because the trial court failed to strictly comply with Utah R. Crim. P. 11(e), which sets out the requirements for a lawful guilty plea. The district court held that the trial court complied with rule 11(e) and that, even if it did not, the error did not amount to good cause to allow Lovell to withdraw his plea because Lovell did not show that but for the error he would not have pled guilty. The Supreme Court reversed, holding (1) the trial court failed to strictly comply with rule 11(e) because the record did not contain statements that clearly and unequivocally informed Lovell of his right to be presumed innocent or his right to a public trial by an impartial jury, and (2) under the "good cause" standard, the trial court's error to strictly comply with rule 11(e) was an error that required reversal. Remanded. View "State v. Lovell" on Justia Law

Curtis Allgier was charged with aggravated murder, disarming a peace officer, aggravated escape, aggravated robbery, and aggravated attempted murder. While Allgier's case was pending, the district court received a letter written by an inmate in county jail alleging that Allgier had admitted his guilt to the inmate. After the court provisionally sealed the letter, the local media filed a motion to unseal the letter. The district court granted the motion, concluding that the letter was a court record under the Utah Code of Judicial Administration (UCJA) and that the public had a right of access to the letter. The Supreme Court granted Allgier's petition for interlocutory appeal of the district court's ruling. The Court affirmed the district court's decision to unseal the letter, holding (1) the district court correctly determined that the letter at issue was entitled to a presumptive right of public access under the UCJA, and (2) the district court correctly concluded that Allgier failed to overcome that presumptive right of public access. View "State v. Allgier" on Justia Law

A highway patrol trooper noticed a car driven by Vance Morris did not have a visible license plate. Once he pulled Morris over, the trooper realized the car had a valid temporary registration tag displayed in its rear window. The trooper approached and spoke to Morris, ultimately gathering evidence leading to Morris's conviction for, inter alia, possession of a controlled substance and driving under the influence of alcohol or drugs. The court of appeals reversed, concluding that once the trooper realized his mistake, he lost the reasonable suspicion that justified the traffic stop, and any contact or further detention of Morris was unreasonable. The Supreme Court reversed, holding (1) when an officer acting in good faith is reasonably mistaken about the grounds for a traffic stop, he may initiate contact with the driver to explain his mistake but may not detain the driver any further, and, if during this encounter, new reasonable suspicion of criminal activity arises, the officer may act accordingly; and (2) because the trooper's stop was based on an objectively reasonable mistake of fact, he was allowed to approach Morris, and the odor of alcohol detected during this encounter allowed the trooper to constitutionally detain Morris further. View "State v. Morris" on Justia Law

Defendant Douglas Lovell was convicted of aggravated murder. Following the entry of his guilty plea, Lovell moved to withdraw it. The district court initially held the motion was untimely, but the Supreme Court reversed that holding and remanded the case. In the district court, Lovell argued he had good cause to withdraw his plea because (1) the trial court failed to strictly comply with Utah R. Crim. P. 11(e), which sets out the requirements for a lawful guilty plea, and (2) there was good cause for him to withdraw his plea because his trial counsel was ineffective. The district court (1) held that the trial court complied with rule 11(e) and even if it did not, the error did not amount to good cause to allow Lovell to withdraw his plea because Lovell did not show that but for the error he would not have pled guilty; and (2) rejected Lovell's claims of ineffective assistance of counsel. On appeal, the Supreme Court reversed the judgment of the district court, holding that the trial court's failure to strictly comply with rule 11(e) constituted good cause to allow Lovell to withdraw his guilty plea. View "State v. Lovell" on Justia Law

Chance Robinson was charged with unlawful possession or use of a controlled substance based on the presence of methamphetamine in his bloodstream. The charge was grounded on provisions of the Utah Controlled Substances Act that make it unlawful for any person to "knowingly and intentionally" have "any measurable amount of a controlled substance in [his or her] body." Robinson pleaded guilty to the charges. On appeal Robinson argued that Utah's measurable amount provision violates the Utah and United States Constitutions. The Supreme Court affirmed the decision of the district court, holding (1) the provision does not violate the due process or the uniform operation of laws clause of the Utah Constitution; (2) the provision does not violate the constitutional principles set forth in Robinson v. California because it punishes the act of using or being under the influence of a controlled substance while in utah and requires the State to prove that such use was knowing and intentional; and (3) the provision does not violate the Due Process Clause of the Fourteenth Amendment. View "State v. Robinson" on Justia Law

Defendant-Appellant Jeffrey Lenkart was charged with rape, forcible sodomy and two counts of sexual abuse. A jury convicted him on all counts, and he was sentenced to concurrent prison terms. Following his sentencing hearing, Defendant moved to arrest judgment and filed a motion for a new trial. The court denied his motion. On appeal, Defendant raised several errors at trial, including the denial of his motion for a new trial. The Supreme Courtâs review of the record found that Defendant received ineffective assistance of counsel when his trial counsel failed to investigate and present important exculpatory evidence. The Court reversed Defendantâs conviction, and remanded the case for a new trial.

Victims-Appellants T.C. and N.C. are the minor victims of sexual abuse perpetrated by their adopted older brother Zachariah Clark. As part of the restitution ordered during sentencing, the trial court required the defendant to pay the costs of the victimsâ therapy. But as defendant was also sentenced to prison, he had no means to pay those costs. Because defendant was adopted through the Utah Division of Child and Family Services (DCFS), Appellants requested that DCFS be ordered to pay their treatment costs pursuant to state law. That request was ultimately denied. On appeal, Appellants raise several grounds for challenging the district courtâs refusal to order DCFS to pay for their treatment. The Supreme Court did not reach the merits of these contentions because it found that the Appellants had no statutory right to appeal the decision.

Petitioner-Defendant Brenda White was charged with the attempted murder of her ex-husband after she chased him and hit him with her car at his workplace. Petitioner filed a pretrial motion asking the judge to instruct the jury on the extreme emotional distress defense, arguing that on the date of the incident, extreme sets overwhelmed her ability to act rationally and caused her to lose all self-control. The trial court denied her motion, and the appellate court affirmed the trial court. On review of the case, the Supreme Court found that the appellate court applied the wrong standard when it evaluated the availability of the extreme emotional distress defense, it reversed the court's decision and remanded the case to the trial court to reevaluate evidence in support of the defense.