Justia Criminal Law Opinion Summaries

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 Supreme Court affirmed Defendant’s conviction of rape and forcible sexual assault of his wife, holding that a single error occurred below, and the error was not prejudicial.Specifically, the Court held (1) Defendant failed to preserve for appeal his argument that the trial judge violated his constitutional rights by making comments to the jury pool about the O.J. Simpson case; (2) the trial court did not err in concluding that alleged sexual partner evidence created a danger of unfair prejudice that substantially outweighed the evidence’s probative value; (3) the trial court did not err in admitting evidence of Defendant’s prior bad acts or limiting defense counsel’s cross-examination of the victim on that point; and (4) Defendant was not prejudiced by his trial counsel’s failure to object to the trial judge’s comments to the jury. View "State v. Beverly" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of child abuse homicide, holding that Defendant’s challenges to expert testimony provided in his case would not receive consideration and that the district court properly denied Defendant’s motion to suppress. The Court, however, took the opportunity provided in this case to rebuke sole reliance on the factors set forth in Salt Lake City v. Carter, 664 P.2d 1168 (Utah 1983) for the determination of whether an individual is in custody for purposes of Miranda v. Arizona, 384 U.S. 436 (1966) and clarified the role these factors play going forward in order to bring courts in lockstep with the United States Supreme Court as to this determination. View "State v. Fullerton" on Justia Law

In this criminal case, the Supreme Court held that the court of appeals erred in accumulating errors that, standing alone, had no potential to cause harm, and thus reversed the court of appeals’ determination of cumulative error and remanded the case for the court of appeals to make a meritorious determination on Defendant’s motion to suppress.Defendant was convicted of two drug-related counts. After Defendant was convicted, the trial court stated that it was considering granting a new trial because of defense counsel’s ineffectiveness and appointed separate conflict counsel to represent Defendant on the issues it raised. The trial court declined to grant a new trial. Defendant appealed, asserting that his trial counsel provided ineffective assistance during the jury selection and motion stages and that the trial court erred in its dealings with conflict counsel. The court of appeals concluded that none of Defendant’s three claims of error warranted reversal on its own but that the cumulative effect of the errors warranted a new trial. The Supreme Court reversed, holding (1) the errors could not cumulate into reversible error; and (2) because the trial court did not determine whether the motion to suppress was meritorious, the case must be remanded to the court of appeals to make this determination. View "State v. Martinez-Castellanos" on Justia Law

The Supreme Court dismissed the interlocutory appeal brought by Defendant challenging the district court’s decision to quash a subpoena Defendant sought seeking against his alleged victim to testify at his preliminary hearing, holding that the decision had been mooted and that the Court lacked jurisdiction to address the district court’s decision to bind Defendant over for trial.Defendant appealed the district court’s decision to quash the subpoena but did not appeal the district court’s determination that probable cause existed for him to face trial. Because the decision Defendant appealed had been mooted by the subsequent bindover and the Supreme Court lacked jurisdiction to consider the bindover decision, the Court dismissed this appeal and remanded the case. View "State v. Hernandez" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of reckless aggravated abuse of a vulnerable adult and interference with an arresting officer, holding that the district court did not err in excluding evidence of the victim’s prior sexual misconduct and correctly instructed the jury.Defendant received a sentence enhancement for his convictions because he qualified as a habitual violent offender. On appeal, Defendant argued that the district court erred in excluding the victim’s prior sexual misconduct evidence and in instructing the jury. The Supreme Court found no error as to these issues. Defendant also argued that Utah’s aggravated abuse of a vulnerable adult statute was unconstitutionally vague and that Utah’s habitual offender statute violated the Utah Constitution’s cruel and unusual punishment clause and the double jeopardy clause. The Supreme Court disagreed, holding that Utah’s aggravated abuse statute is not unconstitutionally vague and that Utah’s habitual violent offender statute is constitutional. View "State v. Tulley" on Justia Law

In this murder case, the Supreme Court clarified the correct standard for extreme emotional distress.Defendant was convicted of first-degree murder for viciously torturing his girlfriend, ultimately causing her death. Defendant argued that he was under extreme emotional distress at the time of the murder. On appeal, the court of appeals concluded that the trial court abused its discretion by not admitting statements under Utah R. Evid. 106 that Defendant made to a detective that he argued would have supported his claim for a reduced charge based on special mitigation for extreme emotional distress but that the error was harmless. The Supreme Court vacated the portions of the court of appeals’ decision that dealt with Rule 106 and the standard for extreme emotional distress, clarified the correct standard for extreme emotional distress, and affirmed the harmlessness determination of the court of appeals on affirmative grounds. View "State v. Sanchez" on Justia Law

The Pattern of Unlawful Activity Act, Utah Code 76-10-1601 to 1609, does not prevent the State from using evidence of acts on which the statute of limitations has expired to prove a pattern of unlawful activity.Defendant was charged with, inter alia, one count of participating in a pattern of unlawful activity. The State further alleged that Defendant had committed securities fraud and that some of those crimes were part of his pattern of unlawful activity. Defendant moved to exclude a number of the alleged acts on the basis that the statute of limitations had run. The district court granted the motion, agreeing with Defendant’s argument that a pattern of unlawful activity cannot be based on crimes that the State could not separately charge because they were time-barred. The Supreme Court reversed and remanded, holding that the best reading of the Act permits the State to base a pattern of unlawful activity on crimes on which the statute of limitations has expired. View "State v. Stewart" on Justia Law

The Supreme Court affirmed Defendant’s conviction of rape of a child, holding that each of Defendant’s claims on appeal failed.Specifically, the Court held (1) this Court declines to consider whether the district court erred in relying upon each of the factors previously articulated in State v. Shickles, 760 P.2d 291 (Utah 1998), to determine the admissibility of Defendant’s previous acts of child molestation because review of this claim was precluded by the invited error doctrine; (2) the district court did not err in admitting evidence of Defendant’s prior acts of child molestation; and (3) Defendant’s claim of ineffective assistance of counsel failed because he did not show that any of counsel’s alleged deficiencies constituted deficient performance and resulted in prejudice. View "State v Ring" on Justia Law

The Supreme Court overruled the relevant portions of State v. Finlayson, 994 P.2d 1243 (Utah 2000), and State v. Lee, 128 P.3d 1179 (Utah 2006), that set forth and recapped the common-law merger test and announced that the controlling test is set forth in Utah Code 76-1-402(1).Defendant was convicted of one count of aggravated assault and one count of aggravated kidnapping. On appeal, Defendant argued that the two convictions should have merged pursuant to State v. Finlayson, P.2d 1243 (Utah 2000), and that his trial counsel rendered ineffective assistance by not asking for an order to that effect. The court of appeals affirmed, holding that trial counsel was not ineffective because the convictions did not, in fact, merge. The Supreme Court affirmed, holding that, in view of the decision announced today, the court of appeals did not err in determining that Defendant’s trial counsel was not ineffective. View "State v. Wilder" on Justia Law