Justia Criminal Law Opinion Summaries

A man was charged with solicitation, conspiracy, and attempted murder after allegedly directing three women, with whom he had a polygamous relationship, to kill a fourteen-year-old girl, C.G., and her parents. The motive for the murder plot was to prevent C.G. from testifying in a pending rape case against him. The alleged plan involved the women breaking into the family’s home, but it was foiled when they were discovered, leading to their arrest. The prosecution sought to introduce evidence at trial regarding the rape case involving C.G., the defendant’s prior conviction for raping one of the co-conspirators, and the nature of his relationship with all three women, including his manipulative and coercive behavior.The Third District Court for West Jordan considered the defendant’s motion in limine to exclude this evidence. The court ruled that evidence about the rape case involving C.G. was intrinsic to the current charges, so not subject to Utah Rule of Evidence 404(b), but excluded most details about that case as irrelevant or unduly prejudicial under rules 401, 402, and 403. The court also excluded evidence of the prior rape conviction, finding it irrelevant and inadmissible under 404(b) and 403, and further excluded detailed evidence of manipulation and control over the women as unfairly prejudicial.The Supreme Court of the State of Utah granted the State’s petition for interlocutory review. The court affirmed the exclusion of the prior rape conviction under rule 403, finding its prejudicial effect outweighed its probative value. However, it held that the district court exceeded its discretion in excluding evidence about the rape case involving C.G. and the defendant’s manipulation of the women. The court adopted the rule that acts intrinsic to the charged crime are not “other acts” under 404(b), and found the probative value of this evidence was not substantially outweighed by unfair prejudice. The Supreme Court reversed the exclusions (except for the conviction) and remanded for further proceedings. View "State v. Blackwing" on Justia Law

The case concerns a criminal defendant charged with murder after an altercation in which the victim, following an argument at his own apartment, was stabbed twice in the back and later died. The defendant claimed self-defense, asserting that he acted to protect himself during a struggle after the victim re-entered the apartment and ended up on top of him. The defendant moved for a pretrial justification hearing under a Utah statute that allows the district court to determine, before trial, whether a defendant’s use of force was justified.The Third District Court held an evidentiary hearing on the defendant’s motion. At that hearing, the defendant provided both a written proffer of facts and attached exhibits, including a preliminary hearing transcript, but did not testify. The district court determined that a mere proffer of facts was insufficient and that the statutory burden required the defendant to present evidence supporting each element of the justification claim. After considering both the proffer and the exhibits, the court found that the defendant’s evidence did not show he subjectively believed the force he used was necessary to defend himself, and thus the court denied the motion to dismiss.On interlocutory appeal, the Supreme Court of the State of Utah addressed the procedural requirements of the pretrial justification statute. The court held that a defendant seeking a pretrial determination of justification must present evidence—rather than mere factual proffers—that, if believed, would be legally sufficient to satisfy each element of the justification defense. The court clarified that this is a burden of production, not a burden of proof. Applying this standard, the court concluded that the defendant failed to produce evidence supporting each element of self-defense and affirmed the district court’s denial of the motion to dismiss. View "State v. Jennings" on Justia Law

A woman arrived at a hospital emergency room in the early morning, reporting that she had just been raped nearby. While waiting to be treated, she spoke with a police officer who asked her basic questions about the location, identity, and description of the perpetrator. The woman, visibly distressed and still processing the traumatic event, spontaneously provided additional details about the assault. Later, a Sexual Assault Nurse Examiner (SANE) conducted a medical exam, gathering information to both treat her and document injuries, and recorded the woman's statements about the assault in a standard report. The woman later died from unrelated causes.After the woman’s death, the State charged Arthur Wayne Najera with aggravated kidnapping and aggravated assault. Since the woman could not testify at trial, the State sought to admit her statements to both the officer and the nurse. Najera objected, arguing that admitting these statements would violate his Sixth Amendment Confrontation Clause rights and the rule against hearsay. The Third District Court, Salt Lake County, held several hearings and ultimately admitted both sets of statements, finding them nontestimonial and falling under the excited utterance and medical treatment exceptions to hearsay. Najera then petitioned for an interlocutory appeal.The Supreme Court of the State of Utah reviewed the interlocutory order. It held that the woman’s statements to the officer were nontestimonial because the primary purpose of the interaction was to assess the situation for immediate safety, not to collect evidence for prosecution. Those statements were also admissible as excited utterances. The court further held that the statements to the nurse were primarily for medical treatment under the circumstances and thus were also nontestimonial; they were admissible under the hearsay exception for medical diagnosis or treatment. The court affirmed the lower court’s rulings admitting both sets of statements. View "State v. Najera" on Justia Law

A man was charged with murder after fatally shooting another individual in a restaurant. The defendant admitted to the shooting but claimed he acted in self-defense, believing the victim was reaching for a weapon, though the victim was unarmed. The incident followed a series of escalating personal disputes involving the defendant, his friend, and the victim. On the night of the shooting, the defendant and his companions sought out the victim at a restaurant, where a confrontation ensued, culminating in the shooting.The case was tried in the Third District Court, Salt Lake County. At trial, the defendant requested a jury instruction clarifying that actual danger is not required for self-defense—only the appearance of danger is necessary. The court declined to give this specific instruction, reasoning that the concept was already covered by the standard self-defense instructions. The defendant’s counsel was permitted to argue this point in closing. The jury convicted the defendant of murder and felony discharge of a firearm. The defendant appealed, arguing that the trial court erred in refusing his proposed instruction and that his counsel was ineffective for not objecting to witnesses referring to the decedent as “victim” and to the admission of an emotional 911 call.The Supreme Court of the State of Utah reviewed the case. It held that the district court did not abuse its discretion in refusing the defendant’s proposed jury instruction, as the instructions given adequately covered the law of self-defense. The court also found that the defendant did not receive ineffective assistance of counsel, as the use of the term “victim” by witnesses was not unreasonable in context, and the admission of the 911 call did not prejudice the outcome. The Supreme Court affirmed the convictions. View "State v. Hunt" on Justia Law

Police searched Franklin James’s apartment and found illegal drugs, drug paraphernalia, and firearms. The State charged him with eleven counts related to these items. James entered a plea agreement, pleading guilty to three counts in exchange for the dismissal of the remaining charges. Both parties agreed to recommend probation so James could receive drug treatment, and James wrote letters to the court expressing remorse. At sentencing, the district court rejected the probation recommendation, citing James’s criminal history and stating that treatment would be available in prison. The court sentenced James to prison and did not invite him to speak before sentencing, nor did James request to do so.James appealed to the Utah Court of Appeals, arguing that the district court violated his constitutional and statutory right to allocution by not allowing him to address the court before sentencing. He also claimed the court abused its discretion by disregarding the unanimous recommendation for probation. The court of appeals found that the failure to invite allocution was plain error and, following the Tenth Circuit’s approach in United States v. Bustamante-Conchas, held that James demonstrated prejudice simply by showing the denial of his right to allocute. The court vacated his sentence and did not reach the abuse-of-discretion claim.The Supreme Court of the State of Utah reviewed the case and reversed the court of appeals. It declined to adopt the Tenth Circuit’s rule that allocution error alone demonstrates prejudice in Utah’s sentencing regime, which differs from the federal system. The court held that, in Utah, a defendant must show case-specific prejudice from denial of allocution, and James failed to do so. The case was remanded for the court of appeals to consider James’s remaining claim regarding abuse of discretion in sentencing. View "State v. James" on Justia Law

A man was charged with multiple offenses, including aggravated sexual assault and aggravated assault, after an incident in which a woman alleged he raped her at gunpoint in his car. At trial, the woman and the defendant gave conflicting accounts: she described a violent, non-consensual encounter involving threats and physical force, while he claimed the encounter was consensual. Physical evidence, including injuries documented by a sexual assault nurse examiner (SANE), and corroborating witness testimony supported the woman’s account. The jury convicted the defendant of aggravated sexual assault and aggravated assault, and he was sentenced to concurrent prison terms.Following his conviction, the defendant pursued posttrial motions in the Third District Court, including claims of a Brady violation and ineffective assistance of trial counsel. The trial court denied these motions after an evidentiary hearing. On direct appeal, the Utah Court of Appeals affirmed the convictions, and the Supreme Court of the State of Utah later affirmed on certiorari, rejecting arguments related to jury instructions and the alleged Brady violation.The defendant then filed a petition for postconviction relief, later amended to include claims of due process violations, the right to present a complete defense, and ineffective assistance of both trial and appellate counsel. The State moved for summary judgment, and the defendant filed a combined opposition and cross-motion for summary judgment. The postconviction court granted the State’s motion, struck the defendant’s cross-motion as procedurally improper, and found the defendant’s claims either procedurally barred or lacking in prejudice.On appeal, the Supreme Court of the State of Utah affirmed the postconviction court’s grant of summary judgment for the State and its decision to strike the defendant’s cross-motion. The Court clarified that while postconviction petitioners may not combine a response and a motion in a single document, nothing in the Post-Conviction Remedies Act or Utah Rules of Civil Procedure prohibits petitioners from filing their own motions for summary judgment. View "Newton v. State" on Justia Law

A man was arrested after being found in Oregon with a seventeen-year-old girl who had been reported missing in Utah. Prior to her disappearance, the girl had exchanged numerous messages with the man and discussed plans to be together. After their apprehension, the girl gave statements in both Oregon and Utah, initially indicating that she had lied about her age but later stating that the man knew she was seventeen and had coerced her into leaving and engaging in sexual acts. Based on her statements, the State of Utah charged the man with multiple felonies, including aggravated kidnapping and sexual offenses. A magistrate issued a no-bail warrant, and the district court later denied the man’s motion for pretrial release, finding substantial evidence for the charges and determining he posed a danger and flight risk.The First District Court in Logan, Utah, initially denied the defendant’s motion for pretrial release, and he did not appeal that decision. Several months later, he filed a motion to modify the pretrial detention order, arguing that new DNA evidence constituted a material change in circumstances. The district court denied this motion, finding no material change, and the defendant then filed a direct appeal from this denial.The Supreme Court of the State of Utah reviewed whether it had jurisdiction to hear an immediate appeal from the denial of a motion to modify a pretrial detention order. The court held that under Utah Code § 77-20-209, a defendant has a right to an immediate, expedited appeal only from a pretrial status order that initially orders detention, not from a denial of a motion to modify such an order. Because the defendant did not appeal the original detention order and did not seek interlocutory review of the denial of his motion to modify, the court concluded it lacked jurisdiction and dismissed the appeal. View "State v. Harris" on Justia Law

In this case, the defendant was charged in 2022 with two counts of sexual abuse of a child, based on allegations by C.R. that the abuse occurred between 1988 and 1990. During the investigation, C.R. recalled being pulled out of class in seventh grade and questioned about the abuse. The defendant moved to dismiss the charges, arguing that the statute of limitations had expired because C.R.’s communication in seventh grade constituted a report to law enforcement, triggering the limitations period under the statute in effect at the time.The Third District Court for Salt Lake County held an evidentiary hearing on the motion. The State presented testimony from a detective and a records director, but no records of a report from the relevant period were found, and witnesses explained that recordkeeping practices at the time were inconsistent. The defense called former law enforcement officers who testified that not all reports were documented. The district court, relying on the Utah Court of Appeals’ decision in State v. Pierce, concluded that because the evidence was not clear enough to resolve the statute of limitations issue as a matter of law, the question should be submitted to the jury. The court denied the motion to dismiss and reserved the issue for trial.On interlocutory appeal, the Supreme Court of the State of Utah held that the district court erred by reserving the statute of limitations issue for the jury. The Supreme Court clarified that under Utah Code section 76-1-306, the judge—not the jury—must determine by a preponderance of the evidence whether a prosecution is time-barred. The court reversed the district court’s order and remanded the case for the district court to make the necessary factual findings and apply the correct legal standard. The Supreme Court left to the district court’s discretion whether to take additional evidence on remand. View "State v. Smith" on Justia Law

Two individuals engaged in a recurring scheme to steal merchandise from Walmart. Their method involved purchasing items, then re-entering the store to take identical items without paying, using the original receipt as false proof of purchase if confronted. The stolen goods were then returned to different Walmart locations for cash or gift cards. After being caught, one of the participants pled guilty to two third-degree felonies and admitted that Walmart suffered over $10,000 in damages due to their actions.In the Third District Court, Salt Lake County, the defendant agreed in his plea to pay restitution, suggesting it should be split with his codefendant. At sentencing, he did not dispute the total damages or his responsibility but argued that the restitution should be apportioned equally between him and his codefendant based on comparative fault principles, as he believed both were equally culpable. The district court rejected this argument, holding that precedent from the Utah Court of Appeals required joint and several liability, and ordered both defendants to be responsible for the full amount until it was paid in full.The Utah Supreme Court reviewed whether the Crime Victims Restitution Act allows a sentencing court to apportion restitution among codefendants based on comparative fault, or whether each must be held jointly and severally liable for the damages proximately caused. The court held that the Act requires each defendant to pay restitution for the entire amount of damages proximately caused by their criminal conduct, even if those damages overlap with amounts owed by codefendants. The court concluded that comparative fault apportionment is not permitted under the Act and affirmed the district court’s order imposing joint and several liability for the full restitution amount. View "State v. Debrok" on Justia Law

In 1988, a man was convicted of first-degree murder and sentenced to death. Decades later, after exhausting his appeals, he was diagnosed with vascular dementia, a progressive neurocognitive disorder that impairs memory and cognitive function. When the state sought an execution warrant in early 2024, he petitioned the court, arguing that his dementia rendered him incompetent to be executed under the Eighth Amendment, which prohibits executing individuals who cannot rationally understand the reason for their execution.The Third District Court in Salt Lake County held an evidentiary hearing, where multiple experts agreed he had vascular dementia and noted a decline in his cognitive abilities. However, the court found he was still competent to be executed, concluding he could rationally understand the reason for his death sentence. The defendant appealed and requested a stay, which was denied. Subsequently, he filed a new petition for reevaluation, supported by recent expert reports and observations indicating a rapid decline and new inability to understand the connection between his crime and punishment. The district court denied this petition, finding no substantial change in circumstances or significant question about his competency, and issued an execution warrant.The Supreme Court of the State of Utah reviewed the case. It held that, under Utah law, a successive petition to reopen competency proceedings must make a prima facie showing of a substantial change in circumstances and raise a significant question about competency. The court found that the district court erred by weighing rebuttal evidence at the threshold stage and by concluding the new petition did not meet the statutory requirements. The Supreme Court reversed the order denying reevaluation, vacated the execution warrant, and remanded for further proceedings. The appeal of the initial competency order and one extraordinary writ petition were deemed moot. View "State v. Menzies" on Justia Law