Justia Criminal Law Opinion Summaries

Petitioner was convicted of aggravated murder and sentenced to death. The Supreme Court affirmed the conviction and sentence. Petitioner subsequently filed a petition for postconviction relief, alleging that his counsel provided ineffective assistance at trial. The postconviction court granted summary judgment in favor of the State. Petitioner filed a notice of appeal in his postconviction proceedings and then filed a Utah R. Civ. P. 60(b) motion to set aside the postconviction court’s final judgment. The postconviction court denied the motion. The Supreme Court consolidated the appeals and affirmed the postconviction court’s grant of summary judgment and denial of Rule 60(b) relief, holding (1) Petitioner failed to raise a genuine issue of material fact for each of his ineffective assistance of counsel claims; and (2) the postconviction court did not abuse its discretion when it denied Petitioner’s motion for relief from judgment pursuant to Rule 60(b). View "Honie v. State" on Justia Law

Defendant pled guilty to unlawful sexual conduct with a minor. Defendant later moved to withdraw his guilty plea based upon ineffective assistance of counsel and a violation of Utah R. Crim. P. 11, arguing that his plea was not knowing or voluntary because neither his defense counsel nor the trial court informed him that his guilty plea carried with it the requirement that Defendant register on the state’s sex offender registry. The district court denied Defendant’s motion to withdraw, concluding that neither defense counsel nor the district court had an obligation to inform him of the registration requirement because the registration requirement was a collateral consequence of the guilty plea. The Supreme Court affirmed, holding that the requirement to register as a sex offender is properly classified as a collateral consequence of a defendant’s guilty plea, and therefore, neither defense counsel nor the trial court in this case was constitutionally obligated to inform Defendant of the registration requirement before his guilty plea was accepted as knowing and voluntary. View "State v. Trotter" on Justia Law

After a jury trial, Frank and Joan Steed, husband and wife, were each convicted of three counts of failure to file a proper tax return and one count of engaging in a pattern of unlawful activity. The failure-to-file statute requires proof that a defendant failed to file with one of three specific intents. The Steeds moved to arrest the judgment largely on the same grounds upon which they relied in a previously denied motion to dismiss. Specifically, the Steeds contended that the State failed to provide sufficient evidence of two of the three specific intent alternatives. Ultimately, the trial court submitted only the two contested intent alternatives to the jury and excluded the remaining intent alternative. The Supreme Court reversed the Steeds’ convictions, holding (1) the State presented insufficient evidence of the two contested intent alternatives; (2) because the court excluded the single supported intent alternative and submitted the two unsupported intent alternatives to the jury, there was insufficient evidence to support the verdicts; and (3) because the pattern counts were contingent on the failure-to-file convictions, the pattern counts, along with the failure-to-file convictions, must be reversed. View "State v. Steed" on Justia Law

After a jury trial, Appellant was convicted of murder and child abuse for the death of her two-year-old son, Alex. Appellant appealed her convictions on several grounds. The Supreme Court affirmed, holding (1) a preponderance of the evidence is required to admit evidence of prior bad acts, and the trial court did not abuse its discretion in admitting evidence of prior child abuse under Utah R. Evid. 404(b); (2) Appellant’s defense counsel was not ineffective for, among other things, deciding not to introduce expert testimony regarding Battered Woman’s Syndrome because the trial strategy he selected was objectively reasonable; and (3) there was no cumulative error. View "State v. Lucero" on Justia Law

After a jury trial, Defendant was convicted of aggravated murder, desecration of a body, kidnapping, and aggravated kidnapping. Defendant was sentenced to life without parole for his murder conviction. Defendant appealed, arguing, among other things, that it was error for his case to be tried in Cache County with Box Elder County jurors. The Supreme Court affirmed Defendant’s conviction of and sentence for aggravated murder and desecration of a body but reversed and vacated his kidnapping and aggravated kidnapping convictions, holding (1) the trial judge did not abuse his discretion in deciding to hold the trial in Cache County with a jury consisting of residents of neighboring Box Elder County; and (2) because Defendant’s kidnapping and aggravating kidnapping convictions merged, the kidnapping conviction should have been vacated, and Defendant’s aggravated kidnapping conviction should have merged with his aggravated murder conviction. View "State v. Nielsen" on Justia Law

Defendant pled guilty to criminally negligent automobile homicide and driving under the influence of alcohol, reserving his right to challenge the denial of his motion to suppress evidence obtained through a blood draw. Defendant’s blood was drawn after the police were issued eWarrants through the Utah Criminal Justice Information System. On appeal, Defendant argued that because the affidavits submitted by the police in order to obtain the warrants were not supported by an oath or affirmation, as required by both the Utah and United State constitutions, the warrants were unconstitutional. The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress, holding that the affidavits comported with the historical understanding of what constitutes a constitutionally valid “affirmation,” and therefore, the affidavits were constitutionally sufficient to support the issuance of the warrants in this case. View "State v. Gutierrez-Perez" on Justia Law

The State charged Defendant with various crimes, including aggravated burglary and aggravated assault. After the jury was empaneled and sworn and on the second day of trial, the trial judge announced that she was recusing herself and declaring a mistrial. The case was subsequently reassigned for retrial under a new judge. Defendant moved to dismiss the charges against him on the grounds of double jeopardy. The trial court denied the motion, concluding that the mistrial did not act as an acquittal because the mistrial was legally necessary. The Supreme Court reversed, holding (1) the burden to create a record for and sufficiently justify the mistrial fell on the trial court and the State, and, in this case, the legal necessity for a mistrial was not established on the record; and (2) Utah’s constitutional protections against double jeopardy precluded a second trial under such circumstances. View "State v. Manatau" on Justia Law

Appellant was convicted of lewdness involving a child and sexual exploitation of a minor by distribution of child pornography for dropping his pants in front of two young girls, exposing a toddler-sized diaper he was wearing, and in distributing a flyer containing images of children and adolescents wearing diapers. On appeal, Appellant argued, among other things, that the evidence was insufficient to sustain his convictions. The Supreme Court agreed and reversed, holding that, while Appellant’s conduct was deplorable and socially inappropriate, it did not fall to the level of criminal lewdness or sexual exploitation under the criminal definition of those terms as clarified in this opinion. View "State v. Bagnes" on Justia Law

After a jury trial, Defendant was convicted of sexual battery, a misdemeanor. Before trial, the district court ruled that evidence of other sexual misconduct allegations against Defendant was inadmissible. However, during redirect examination of an investigating detective, the prosecutor elicited testimony about other allegations of sexual misconduct against Defendant, which was classified as Utah R. Civ. P. 404(b) evidence. A panel majority of the court of appeals reversed and remanded for a new trial after refusing to apply the presumption of regularity in favor of the State, holding that the district court plainly erred and counsel rendered ineffective assistance in allowing the Rule 404(b) evidence. The Supreme Court reversed without addressing the State’s argument that a gap in the record of a criminal trial should always be interpreted in favor of the State, holding that Defendant’s trial counsel was not ineffective in referencing and admitting the Rule 404(b) evidence, and the district court did not commit plain error in allowing the evidence to be presented. Remanded. View "State v. Bedell" on Justia Law

Defendant was arrested and removed from a home he owned with his wife. Soon afterwards, Defendant's wife obtained a restraining order that prohibited Defendant from going to the family home for 150 days. About three weeks after the restraining order expired, Defendant entered the home and brandished a rifle. Defendant was subsequently charged with aggravated burglary, aggravated assault, and commission of domestic violence in the presence of a child. A magistrate found Defendant could not be bound over on the aggravated burglary charge because there was insufficient evidence that Defendant had relinquished his possessory interest in the family home to render his entry unlawful under Utah's burglary statute. The Supreme Court affirmed, holding (1) an estranged spouse may implicitly relinquish his or her possessory rights to the marital home by voluntarily establishing a separate residence; but (2) in this case, the State did not produce sufficient evidence of voluntary relinquishment. Remanded. View "State v. Machan" on Justia Law