Justia Utah Supreme Court Opinion Summaries

E.M., a fifteen-year-old, was arrested for allegedly killing S.A. and wounding four others in a racially motivated drive-by shooting. The State charged E.M. with multiple felonies, including murder, in juvenile court and sought to transfer the case to district court.The juvenile court held a preliminary hearing where eight witnesses testified. The court found probable cause that E.M. was a principal actor in the murder and analyzed whether retaining jurisdiction was contrary to the best interests of E.M. and the public. The court considered the seriousness of the crime, the aggressive and premeditated nature of the offense, E.M.'s traumatic background, lack of prior criminal record, and the likelihood of rehabilitation. The court noted E.M.'s difficult childhood, marked by extreme trauma, and his progress in detention but also highlighted incidents of racially motivated violence. Ultimately, the court concluded that transferring E.M. to district court was appropriate.The Utah Supreme Court reviewed whether the juvenile court abused its discretion in transferring E.M.'s case. The court emphasized that the Transfer Statute requires a holistic approach, considering all relevant circumstances surrounding the qualifying offense. The court found that the juvenile court appropriately considered the context of the crime, including non-qualifying offenses, to assess the seriousness and premeditated nature of the offense. The court also held that the juvenile court did not err in weighing E.M.'s trauma history as a factor that could impact the likelihood of rehabilitation.The Utah Supreme Court upheld the juvenile court's decision, finding no abuse of discretion in the transfer of E.M.'s case to district court, concluding that it was in the best interests of both E.M. and the public. View "In re E.M." on Justia Law

In 2001, Morris Mullins, then seventeen, killed a seventy-eight-year-old widow, Amy Davis, in her home. He was charged as an adult with rape and aggravated murder. Mullins pled guilty to aggravated murder in exchange for the State dropping the rape charge and not seeking the death penalty. He was sentenced to life without parole (LWOP). At sentencing, the court considered evidence of Mullins's dysfunctional upbringing and psychological evaluations but ultimately imposed a juvenile life without parole (JLWOP) sentence.Mullins later challenged his sentence as unconstitutional, citing the Eighth Amendment and the Utah Constitution. In 2013, he filed a pro se motion to correct an illegal sentence under rule 22(e) of the Utah Rules of Criminal Procedure, arguing that his sentence was unconstitutional under Miller v. Alabama, which held that mandatory JLWOP for juveniles violated the Eighth Amendment. The district court denied his motion in 2016, and Mullins's appeal was delayed until 2020 due to ineffective assistance of counsel.The Utah Supreme Court reviewed the case, focusing on whether Mullins's JLWOP sentence was constitutional. The court held that the sentencing judge's comments suggested ambiguity about Mullins's capacity for change, which undermined confidence in the appropriateness of the JLWOP sentence. The court vacated Mullins's sentence and remanded for resentencing, emphasizing the need to consider Mullins's youth and potential for rehabilitation in light of Miller and its progeny. The court did not find the sentencing statute unconstitutionally vague or the JLWOP categorically unconstitutional but required a more thorough consideration of Mullins's youth and potential for change. View "State v. Mullins" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating the juvenile judge’s bindover order in this case involving a juvenile’s criminal conduct, holding that it was error to excuse Defendant from preserving his claim of judicial bias.The State charged Defendant with three first-degree felonies in juvenile court. The juvenile judge bound over Defendant, who was sixteen years old when he committed the offenses, to the district court to be tried as an adult. Defendant then pled guilty to lesser charges. While serving his prison sentence, Defendant moved to reinstate the time to appeal his bindover order, which the district court granted. Defendant then argued on appeal that the juvenile judge should have recused herself from his case due to judicial bias. The court of appeals agreed and vacated the bindover order without requiring Defendant to show either that he had preserved his judicial bias claim in the trial court or that an exception to preservation applied. The Supreme Court reversed, holding that Defendant’s judicial bias claim was not exempt from the preservation requirement. View "State v. Van Huizen" on Justia Law

The State filed a petition that charge D.B. as a principal with theft and criminal trespass for entering a construction site and removing a pair of bolt cutters. The juvenile court adjudicated D.B. a delinquent as an accomplice on both counts. The court of appeals affirmed. D.B. filed a petition for writ of certiorari, claiming that he did not receive adequate Sixth Amendment notice that he may be adjudicated delinquent as an accomplice for the charges. The Supreme Court reversed the delinquency adjudication on the criminal trespass charge but affirmed it on the theft charge, holding (1) D.B. received constitutionally adequate notice through trial testimony that he faced accomplice liability for theft; but (2) the juvenile court adjudicated D.B. delinquent as an accomplice for criminal trespass without notice. Remanded. View "D.B. v. State" on Justia Law

Dillon Whitney's mother filed a wrongful death suit against the State after Dillon died while in state custody. The State filed a motion to dismiss, arguing that it was exempt from suit under the incarceration exception to the Governmental Immunity Act of Utah. The federal district court denied the motion, and the State appealed. The Supreme Court accepted certification to answer a question of state law and held (1) a juvenile who is placed in an unsecured community-based proctor home is not incarcerated in a place of legal confinement; and (2) accordingly, the incarceration exception to the State's waiver of its sovereign immunity did not apply in this case, and the State remained potentially liable for damages related to Dillon's death. View "Whitney v. Div. of Juvenile Justice Servs." on Justia Law

The State filed a delinquency petition alleging that a seventeen-year-old girl had engaged in criminal solicitation to commit murder after she asked a stranger to punch her in the stomach to terminate her pregnancy. The juvenile court (1) held that an assault of a woman by punching her in the stomach was a "procedure" intended to terminate her pregnancy and therefore qualified as an abortion under statute; and (2) dismissed the State's petition against the minor because a woman cannot be held criminally liable for seeking an abortion. The Supreme Court reversed, holding that the solicited assault of a woman to terminate her pregnancy was not a "procedure" as contemplated by statute and therefore did not constitute an abortion. Remanded. View "State v. J.M.S." on Justia Law