Justia Criminal Law Opinion Summaries

Articles Posted in Utah Supreme Court
by
The Supreme Court reversed Defendant's conviction as an accomplice to the crime of aggravated murder, holding that it was reasonably probable that the jury would not have convicted Defendant absent three jury instruction errors. The jury instruction discussing the elements for accomplice liability on aggravated murder contained three errors. The court of appeals affirmed the conviction, holding that, in the absence of these errors, there was not a reasonable probability that the jury would have reached a different result. The Supreme Court reversed, holding that there was a reasonable probability that the jury would not have convicted Defendant in the absence of the three errors in the jury instruction that provided the basis for Defendant's conviction. View "State v. Grunwald" on Justia Law

by
The Supreme Court reversed the judgment of the district court dismissing Appellant's claim brought under the Post-Conviction Remedies Act (PCRA), holding that, contrary to the conclusions of the district court, Appellant's petition was not barred because his initial petition did not count as a "previous request for post-conviction relief" under Utah Code 78B-9-106(1)(d). In 2013, Appellant was convicted of aggravated sexual abuse of a minor. In 2017, Appellant submitted a petition in the Second District Court of Utah seeking to challenge his conviction. Appellant subsequently withdrew his petition under Utah R. Civ. P. 41(a)(1)(A). Later, Appellant filed a new petition in the Second District Court. The district court dismissed the petition, concluding that it was procedurally barred because it asserted claims that were, or could have been, raised or addressed in a previous request for post-conviction relief. The Supreme Court reversed, holding that there is no "previous request for post-conviction relief" where the action was initiated but voluntarily dismissed under Rule 41(a)(1)(A). View "Hand v. State" on Justia Law

by
The Supreme Court reversed the decision of the court of appeals reversing Defendant's conviction of aggravated robbery on the ground that the legal framework established in State v. Ramirez, 817 P.2d 774 (Utah 1991), is no longer viable and reinstated the jury verdict on the alternative basis that any arguable error in admitting eyewitness identification evidence in this case was harmless. Defendant was convicted based on eyewitness identification testimony and other evidence admitted at trial. The court of appeals reversed the conviction under the reliability factors set forth in Ramirez and on the ground that the improperly admitted eyewitness identifications were not harmless beyond a reasonable doubt. The court of appeals, however, also raised concerns about the viability of the standard set forth in Ramirez, indicating that the Ramirez framework must be revisited. The Supreme Court endorsed the need for revising and updating the factors set forth in Ramirez based on new developments in scientific and legal research regarding the reliability of eyewitness identification testimony. The Court then held (1) admissibility of eyewitness identification testimony is to be measured in the first instance by the rules of evidence; and (2) in this case, any error in admitting such evidence was harmless beyond a reasonable doubt. View "State v. Lujan" on Justia Law

by
The Supreme Court dismissed Appellant's appeal, in which Appellant raised two new arguments, from the district court's denial of his motion to withdraw his plea under Utah Code 77-13-6, the Plea Withdrawal Statute, holding that the Plea Withdrawal Statute prohibited this Court from considering Appellant's unpreserved arguments. Appellant pled guilty to felony driving under the influence. Before sentencing, Appellant moved to withdraw his plea. The district court denied the motion. Appellant appealed and raised two new arguments under the plain error and ineffective assistance of counsel exceptions to the preservation rule. The court of appeals certified the case to the Supreme Court for original appellate review. The Supreme Court held (1) the Plea Withdrawal Statute prevents this Court from considering Appellant's unpreserved arguments; and (2) defendants may not rely on preservation exceptions when appealing the denial of a motion to withdraw a guilty plea. View "State v. Flora" on Justia Law

by
The Supreme Court affirmed the judgment of the court of appeals holding that it acted jurisdiction to hear Defendant's unpreserved claim on appeal, holding that Utah's Plea Withdrawal Statute, Utah Code 77-13-6, bars review of unpreserved claims raised as part of an appeal from the denial of a timely plea-withdrawal motion. Defendant pled guilty to attempted murder. Before he was sentenced Defendant moved to withdraw his plea. The district court denied the motion. Defendant appealed this denial and raised a new challenge under the plain error exception to the preservation rule. The court of appeals concluded that it lacked jurisdiction to entertain Defendant's unpreserved claim. The Supreme Court affirmed, holding that that the Plea Withdrawal Statute bars appellate review of unpreserved claims raised as part of an appeal of a timely motion to withdraw a guilty plea. View "State v. Badikyan" on Justia Law

by
The Supreme Court affirmed the decision of the district court convicting Defendant of two of four counts of sexual exploitation of a minor but reversed the district court on the remaining two convictions, holding that the second and fourth counts of sexual exploitation of a minor did not meet the Sexual Exploitation Act's definition of simulated sexually explicit conduct. Appellant was charged with four counts of sexual exploitation of a minor after he was discovered in his middle school classroom where he taught with scrapbooks containing pornographic images of adults and images of underage, and sometimes nude, girls. Appellant entered a Sery plea of no contest and then appealed. The Supreme Court affirmed Defendant's two of the counts of sexual exploitation of a minor but reversed the district court on the remaining two counts, holding that the district court did not err in interpreting the Act but that there was insufficient evidence to convict Defendant on counts two and four. View "State v. Hatfield" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals concluding that there was sufficient evidence to sustain the charged aggravator for Defendant's aggravated murder conviction and that the district properly denied Defendant's motion for a new trial, holding that there was no error in the proceedings below. On appeal, Defendant argued that there was insufficient to sustain the determination that he placed another person at "great risk of death" when he killed his victim and that the district court abused its discretion in denying his motion for a new trial. The court of appeals affirmed. The Supreme Court affirmed, holding (1) in determining whether a murder was committed under circumstances in which the defendant caused a "great risk of death" to another person Utah Code 76-5-202(1)(c) is satisfied if the great risk of death was created with a "brief span of time" of the act causing the murder and the acts together "formed a concatenating series of events"; (2) there was a reasonable basis for the jury to conclude that Defendant caused a great risk of death to another in the circumstances of the murder in this case; and (3) the district court did not err in denying Defendant's motion for a new trial. View "State v. Sosa-Hurtado" on Justia Law

by
The Supreme Court affirmed the judgment of the district court affirming Defendant's conviction of failure to signal for two seconds and failure to obey traffic control devices, holding that the Utah Constitution does not guarantee Defendant a jury trial for his traffic violations. At the time Defendant was charged, the Utah Code classified the offenses as class C misdemeanors. At the arraignment hearing the City amended both charges to infractions, thereby depriving Defendant of a jury trial. Defendant moved to dismiss the information charging him with infractions, arguing that the Utah Constitution guarantees a right to a jury trial in all criminal prosecutions, including those for infractions. The justice court denied Defendant's motion to dismiss and request for a jury trial and convicted Defendant. On appeal, the district court denied Defendant's motion for a jury trial and convicted him of both charges. The Supreme Court affirmed, holding that minor offenses do not trigger the right to a jury trial under article I section 12 of the Utah Constitution. View "South Salt Lake City v. Maese" on Justia Law

by
The Supreme Court reversed the judgment of the district court issuing an injunction enjoining the implementation of Senate Bill 78 (SB 78) on the grounds that it violates article X, section 8 of the Utah Constitution, holding that State Board of Education members are not employed in the state's education systems and are therefore not covered by article X, section 8. In 2016, the legislature passed SB 78, which makes the office of State Board of Education a partisan office and requires Board members to be elected through the general partisan election process. The district court concluded that Board members hold "employment" in a legal sense in the State's education system and therefore fell within the purview of article X, section 8. Thus, the court concluded, SB 78 was unconstitutional. The Supreme Court reversed the district court and reinstated SB 78, holding that because the Utah Constitution omits Board members from being in a condition of employment in the state's education systems, SB 78 does not violate the Utah Constitution. View "Richards v. Cox" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions for aggravated kidnapping, aggravated robbery, and obstruction of justice, holding that the court of appeals properly concluded that Defendant's free will was not overborne in confessing and making other incriminating statements to the police and properly concluded that a jury instruction given at trial was faulty but did not result in prejudice to Defendant. On appeal, Defendant argued that the court of appeals erred in (1) affirming the trial court's determination that his statements were admissible at trial as impeachment evidence, despite a violation of his Miranda rights, which barred the statements from being used in the Sate's case-in-chief; and (2) erred in affirming his conviction for aggravated robbery despite a jury instruction that incorrectly recited the requisite mental state for the offense. The Supreme Court affirmed, holding (1) the court of appeals correctly affirmed that Defendant's statements to police were voluntary and that his confession and incriminating statements could be used for impeachment purposes in the event that Defendant chose to testify; and (2) the faulty jury instruction did not affect the outcome or the verdict. View "State v. Apodaca" on Justia Law