Justia Utah Supreme Court Opinion Summaries

In this case, Cathy McKitrick, an investigative journalist, sought access to certain records under the Government Records Access and Management Act (GRAMA). The Ogden City Records Review Board ordered the city to release redacted versions of the records. Kerry Gibson, the subject of the records, petitioned the district court to prevent their release. McKitrick intervened in the proceedings and moved to dismiss Gibson's petition for lack of standing. The Supreme Court of the State of Utah held that Gibson lacked standing. Before the district court dismissed the case, McKitrick moved for an award of attorney fees and litigation costs, which was denied by the district court. On appeal, the Supreme Court of the State of Utah reversed the district court’s interpretation of the fee provision but did not hold that McKitrick was entitled to a fee award. Because the district court did not consider substantive aspects of the fee provision, the Supreme Court remanded the case for it to do so. View "McKitrick v. Gibson" on Justia Law

In the case before the Supreme Court of the State of Utah, the appellant, Troy Michael Kell, appealed the district court's dismissal of his second petition for post-conviction relief. Kell, while serving a life sentence for murder, had stabbed another inmate to death in 1994. He was convicted of aggravated murder, a capital offense, and sentenced to death. Following his conviction, Kell filed a petition for post-conviction relief which was dismissed by the district court.Years later, during federal habeas corpus proceedings, Kell's attorneys discovered evidence that three jurors from his trial had communicated with the judge during sentencing deliberations without Kell or either party’s counsel present. One of these jurors remembered the judge stating that it was Kell’s burden to convince the jury that his life should be spared. This new evidence formed the basis of Kell’s second petition for post-conviction relief which he filed in 2018, over five years after the evidence was discovered.The district court dismissed Kell's petition, applying the time and procedural limitations under the Post-Conviction Remedies Act (PCRA) and rule 65C of the Utah Rules of Civil Procedure. Kell argued on appeal that the district court erred in dismissing his petition based on these limitations. He claimed that his delay in filing was due to ineffective assistance of initial post-conviction counsel and that applying the PCRA’s time and procedural bars violated his rights under the Suspension Clause, Due Process Clause, and Open Courts Clause of the Utah Constitution.The Supreme Court of the State of Utah affirmed the district court's decision. The court held that Kell had not shown that any shortcoming of his initial post-conviction counsel excuses the five and a half year delay in bringing this claim after discovering the alleged improper communication between the trial judge and jurors. The court also held that Kell had not demonstrated that the application of the PCRA’s time and procedural bars to his claim violated his constitutional rights. He was unable to show that the application of these bars prevented him from challenging his detention or left him unable to vindicate his substantive rights. View "Kell v. Benzon" on Justia Law

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 determination of the Utah State Tax Commission that the Property Tax Division correctly followed the requirements of the Aircraft Valuation Law, Utah Code 59-2-201 subsection 4, in determining the 2017 value of Delta Air Lines' aircraft, holding that Salt Lake County failed to demonstrate that the Law, as applied to Delta's 2017 assessment, violated the fair market value provision of the Utah Constitution.For tax year 2017, the Division valued Delta's aircraft according to section 59-2-201's preferred methodology. The County appealed, arguing that the valuation did not reflect the fair market value of Delta's aircraft, in violation of the Utah Constitution. The Commission upheld the assessment, concluding that the County did not establish that the Legislature's preferred method of valuation did not reasonably reflect fair market value. The Supreme Court affirmed, holding that the Aircraft Valuation Law was not unconstitutional as applied by the Commission to assess the value of Delta's aircraft for tax year 2017. View "Salt Lake County v. Utah State Tax Commission" 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 granting Robyn Young's motion to dismiss this action brought by Granite School District regarding settlement proceeds Young had received for industrial injuries, holding that the Labor Commission had exclusive jurisdiction over the factual questions at the heart of this reimbursement dispute.Young, a special education teacher, sought workers' compensation for injuries she received at the hands of her students. An administrative law judge awarded Young benefits, finding that Young was permanently and totally disabled and that Young did not have to reimburse Granite with funds she received from a legal settlement she had obtained against medical debt collectors for violations of the Fair Debt Collection Practices Act. Granite then initiated suit for reimbursement from Young under the Utah Workers' Compensation Act. The district court granted Young's motion to dismiss. The Supreme Court affirmed, holding that the district court did not err when it dismissed Granite's complaint because the Workers' Compensation Act assigned the Commission exclusive jurisdiction over this dispute. View "Granite School District v. Young" 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