Justia Utah Supreme Court Opinion Summaries

Seth Clark Jolley was charged with raping T.T. Before his trial, Jolley moved under rule 412 of the Utah Rules of Evidence to determine the admissibility of evidence that he and T.T. had previously engaged in other sexual conduct. Rule 412 generally prohibits the admissibility of a victim’s other sexual behavior but allows exceptions under certain circumstances, such as to prove consent. Jolley filed a motion describing the evidence he sought to admit, stating that either he or T.T. would be its source.The Fourth District Court in Juab County concluded that Jolley had met his burden under rule 412 and that the incidents he wanted to inquire about were proper questions for an in camera hearing. T.T. objected, arguing that Jolley could not use rule 412 to compel her to testify about her alleged sexual behavior at the hearing. The court disagreed and ordered T.T. to testify, reasoning that the purpose of the 412 hearing was to identify the evidence for presentation to a jury.The Supreme Court of the State of Utah reviewed the case and concluded that the district court erred in its interpretation of rule 412. The court held that a party seeking to admit evidence under a rule 412(b) exception cannot compel a victim to testify at a rule 412 hearing. The court emphasized that the purpose of the rule 412 hearing is to give the victim and parties a right to attend and be heard, not to compel the victim to provide testimony. Accordingly, the Supreme Court reversed the district court’s denial of T.T.’s motion to quash Jolley’s subpoena and remanded for further proceedings. View "State v. Jolley" on Justia Law

Quintin Grillone resigned from his position as a police officer in 2014 while under investigation for providing false information to a prosecutor regarding a traffic citation against his mother. The Peace Officer Standards and Training Division (POST) did not learn of the incident until 2019 when Grillone disclosed it in his application to join a new police department. Following an investigation, POST initiated disciplinary proceedings, and an administrative law judge found that Grillone's conduct constituted obstruction of justice. The POST Council then retroactively suspended Grillone’s certification for three years.Grillone sought judicial review by the Utah Court of Appeals, arguing that the disciplinary proceedings were time-barred by the four-year catch-all statute of limitations for civil actions under Utah Code § 78B-2-307(4). He contended that the statute governing POST disciplinary proceedings referred to them as “civil actions,” thus subjecting them to the civil statute of limitations. The court of appeals, however, held that civil statutes of limitation do not apply to administrative disciplinary proceedings absent specific legislative authority and found that the POST statute did not incorporate the civil statute of limitations.The Utah Supreme Court reviewed the case and affirmed the court of appeals' decision. The Supreme Court agreed that civil statutes of limitation are generally inapplicable to administrative disciplinary proceedings unless the legislature indicates otherwise. The Court concluded that the POST statute’s reference to “civil actions” was intended to distinguish POST proceedings from criminal actions, not to incorporate the civil statutes of limitation. Therefore, the disciplinary proceedings against Grillone were not time-barred, and the POST Council’s three-year suspension of his certification was upheld. View "Grillone v. Peace Officer Standards" on Justia Law

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

Haylee Hinton was injured in a car accident caused by another motorist running a red light. She initially sought compensation from her employer’s workers’ compensation insurer and later settled with the motorist’s insurance carrier. Hinton then filed a claim for underinsured motorist benefits with Midwest Family Mutual Insurance, her underinsured motorist coverage provider, and submitted the claim to arbitration as permitted by Utah law.Midwest sought a declaratory judgment from the district court to limit the categories of damages Hinton could recover in arbitration, citing Utah Code section 31A-22-305.3(4)(c)(i), which excludes benefits paid or payable under the Workers’ Compensation Act from underinsured motorist coverage. The district court interpreted the statute to mean that past and future medical expenses and two-thirds of lost wages were payable under workers’ compensation and ruled that Hinton could not recover these categories of damages from Midwest.Hinton petitioned for interlocutory review, arguing that the district court lacked jurisdiction and misinterpreted the statute. The Utah Supreme Court found that the district court had jurisdiction but misinterpreted the statute. The court concluded that “payable” means benefits that can or may be paid to a specific claimant in a particular case, not just categories of damages generally available under workers’ compensation. The court vacated the district court’s order and remanded the matter for further proceedings to determine what benefits remain payable to Hinton under the Workers’ Compensation Act. View "Hinton v. Midwest Family Mutual Insurance" on Justia Law

Several young Utah residents filed a lawsuit challenging statutory provisions and government actions related to fossil fuel development. They claimed that these provisions and actions were designed to maximize fossil fuel development in Utah, which they argued endangered their health and shortened their lifespans by exacerbating climate change. They sought a declaration from the district court that these provisions and actions violated their rights under the Utah Constitution.The government defendants moved to dismiss the case, arguing that the requested relief would not redress the alleged injuries. The Third District Court, Salt Lake County, agreed and dismissed the claims with prejudice, concluding that the plaintiffs lacked standing because their claims were not redressable.The Utah Supreme Court reviewed the case and affirmed the dismissal on the ground that the district court lacked subject-matter jurisdiction. The court found that the challenge to the energy policy provision was moot because the legislature had significantly amended the statute since the complaint was filed. The plaintiffs lacked standing to challenge the remaining statutory provisions because success on those challenges would not provide relief likely to redress their injuries. The court noted that the challenged provisions did not limit the government defendants' discretion in making decisions about fossil fuel development, and thus, striking these provisions would not necessarily lead to less fossil fuel development.The court also held that the challenges to the government defendants' conduct were not justiciable because they were not supported by a concrete set of facts. The plaintiffs had identified general categories of conduct without tying their claims to any specific government actions. The court instructed the district court to modify its ruling to reflect that the dismissal was without prejudice, allowing the plaintiffs the opportunity to refile their claims if they could address the jurisdictional deficiencies. View "Roussel v. State" on Justia Law

In 2016, Monte Cooke was involved in a traffic accident that resulted in one death and serious injury to another person. Cooke was charged with two second-degree felony counts for negligently driving with a measurable amount of a controlled substance in his body, causing death or serious bodily injury. Before his trial, the Utah Legislature repealed and replaced the statute under which Cooke was charged.Cooke filed a motion to dismiss the charges, arguing that he could not be prosecuted under a repealed statute. The Fourth District Court in Provo denied his motion, ruling that Utah’s general saving statute, Utah Code section 68-3-5, protects criminal prosecutions initiated before a statute’s repeal. The Utah Court of Appeals granted Cooke’s petition to appeal the interlocutory order and certified the matter to the Utah Supreme Court.The Utah Supreme Court held that Utah’s general saving statute allows a prosecution to proceed unabated when the statutory basis for the charge is repealed before trial. The court concluded that the plain language of the saving statute indicates that a statute’s repeal does not affect actions already commenced under that statute, including criminal actions. The court also determined that its decisions in Belt v. Turner and its progeny, which require the application of ameliorative sentencing amendments before sentencing, do not preclude this result. Therefore, the court affirmed the district court’s decision to proceed with Cooke’s trial under the repealed statute and remanded the case for further proceedings. View "State v. Cooke" 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

In 2016, Chad Hintze, a registered sex offender, visited a public park, violating his sex offender registry conditions. He was charged with a class A misdemeanor in 2018 while serving a prison sentence for a separate offense. However, the State did not notify Hintze of the charge until March 2020, when he was being considered for parole on the separate offense. The State began prosecuting the misdemeanor in June 2020 after Hintze requested a hearing.Hintze moved to dismiss the charge, claiming his Sixth Amendment right to a speedy trial was violated due to the State's two-year delay, which he argued prejudiced his parole chances. The Third District Court, Salt Lake County, disagreed, finding Hintze's prejudice claim speculative and determining that his speedy trial right was not violated based on the Barker v. Wingo framework. Hintze entered a conditional guilty plea and appealed.The Utah Court of Appeals, in a divided decision, reversed the district court's ruling, concluding that the Barker factors favored Hintze and required dismissal of the case on Sixth Amendment grounds. The State then petitioned the Utah Supreme Court for certiorari review.The Utah Supreme Court reviewed the case and concluded that although the two-year delay was significant, the Barker factors, when appropriately weighed, did not establish a violation of Hintze’s speedy trial right. The court found that the delay, caused by the State's negligence, was not extraordinary, and Hintze's claim of prejudice was speculative. Consequently, the court reversed the court of appeals' decision, reinstated Hintze’s conviction, and remanded the case to the court of appeals for further proceedings on Hintze’s motion to suppress. View "State v. Hintze" on Justia Law

Deon Jennings was arrested and charged with first-degree murder after stabbing Willie Houston twice in the back, resulting in Houston's death. Jennings argued at a bail hearing that he should be released on bail because the State had not presented substantial evidence to support the charge, claiming he did not intend to injure Houston and acted in self-defense. The district court rejected Jennings' arguments and ordered him held without bail. Jennings appealed, and the Utah Court of Appeals affirmed the district court's decision.The Utah Court of Appeals reviewed the case and concluded that the State had presented substantial evidence of the requisite mens rea for first-degree murder. The court noted that Jennings' own statements and the nature of Houston's injuries provided a reasonable basis for a jury to conclude that Jennings intended to cause serious bodily injury to Houston. The court also addressed the issue of self-defense, assuming for the sake of argument that the State had the burden to disprove self-defense at the bail hearing. The court found that the State had met this burden, as Jennings' statements indicated he did not feel threatened by Houston, and the evidence suggested that any belief Jennings might have had that Houston posed an imminent threat was not reasonable.The Utah Supreme Court reviewed the case and affirmed the court of appeals' decision. The Supreme Court held that the State presented substantial evidence of Jennings' intent to cause serious bodily injury to Houston, as required for a first-degree murder charge. The court also agreed that the State had presented substantial evidence disproving Jennings' claim of self-defense, noting that Jennings' own statements and the circumstances of the altercation did not support a reasonable belief that he was acting in self-defense. View "State v. Jennings" on Justia Law

Stephen Rippey pled guilty to one count of aggravated sexual abuse of a child and one count of object rape of a child. He was sentenced to two concurrent prison terms of fifteen years to life. Ten years after his conviction, a district court reinstated Rippey’s time to file a direct appeal. On appeal, Rippey challenged several aspects of his plea, conviction, and sentence, leading the Supreme Court of Utah to address whether the Plea Withdrawal Statute (PWS) is constitutional.The Third District Court in West Jordan initially accepted Rippey’s guilty plea after a colloquy and a signed plea form. Rippey did not move to withdraw his plea before sentencing. He later filed a pro se petition for post-conviction relief under the Post-Conviction Remedies Act (PCRA), listing seventeen claims. The district court dismissed eight claims as frivolous and the remaining claims for failure to state a claim. Rippey’s requests for appointed counsel were denied. The Utah Court of Appeals upheld the district court’s dismissal, concluding that Rippey’s claims were unpreserved except for ineffective assistance of counsel, which lacked merit.The Supreme Court of Utah reviewed the constitutionality of the PWS, specifically subsections (2)(b) and (2)(c). The court held that subsection (2)(b)’s preservation rule and the corresponding waiver in subsection (2)(c) violate the separation of powers under the Utah Constitution. These provisions were deemed procedural, not substantive, and thus beyond the legislature’s authority to enact. The court concluded that the PWS does not bar Rippey’s challenge to his guilty plea, and his appeal is now governed by standard rules of preservation. The court instructed the parties to brief the merits of Rippey’s challenges under these standards. View "State v. Rippey" on Justia Law