Justia Criminal Law Opinion Summaries

Defendant, a New Mexico resident, was arrested in Utah and indicted on federal charges of coercion and enticement of a fifteen-year-old. Defendant was returned to New Mexico to await trial and remained there for more than two years, returning to Utah on a few occasions to attend proceedings in federal court. The federal charges were subsequently dismissed. Thereafter, the State of Utah charged Defendant with enticement of a minor. Defendant moved to dismiss the charge as untimely under the applicable statute of limitations. The district court denied Defendant's motion. At issue on appeal was the applicability of the criminal tolling statute, which tolls the limitations period while a defendant is out of the state. The Supreme Court affirmed, holding that the criminal tolling statute applied to Defendant even though he was present in Utah during the course of the federal court proceedings, as (1) Defendant was only loosely subject to the authority of the State during the federal proceedings against him; and (2) applying the statute to Defendant did not violate the Uniform Operation of Laws provision of the Utah Constitution. View "State v. Canton" on Justia Law

After a jury trial, Defendant was convicted of murder. Fourteen years later, Defendant filed a petition for a post-conviction determination of factual innocence pursuant to Utah's Post-Conviction Remedies Act (PCRA). After an evidentiary hearing, the post-conviction court vacated Defendant's murder conviction, determining (1) the PCRA allows a determination of factual innocence to be based on a combination of newly discovered evidence and previously available evidence; and (2) Defendant established her factual innocence by clear and convincing evidence. The Supreme Court affirmed, holding (1) a post-conviction determination of factual innocence can be based on both newly discovered evidence and previously available evidence; and (2) the State did not properly challenge the post-conviction court's factual findings, and therefore, the post-conviction court's ultimate determination that Defendant was factually innocent was affirmed. View "Brown v. State" on Justia Law

Defendant confessed to helping Glenn Griffin commit murder. The State charged both Griffin and Defendant with the crime. The State prosecuted Griffin first and, concerned that Defendant would invoke his privilege against self incrimination and refuse to testify, offered Defendant use immunity. The district judge subsequently issued an order compelling Defendant to testify, but Defendant refused. Thereafter, the State charged Defendant with three counts of obstruction of justice. After a hearing, the magistrate judge refused to bind Defendant over for trial and dismissed the obstruction of justice charges. The court of appeals affirmed, finding that State had failed to present sufficient evidence of intent to obstruct. The Supreme Court reversed, holding that the evidence was sufficient to bind Defendant over for trial for obstruction of justice. Remanded. View "State v. Maughan" on Justia Law

After a jury trial, Defendant, who was temporarily staying in the spare bedroom of the victim's father's house, was convicted of aggravated sexual abuse of a child. Defendant's conviction was based on the holding that he occupied a "position of special trust" in relation to the victim under Utah Code 76-5-404.1(4)(h). The district court and court of appeals both held Defendant was an "adult cohabitant" of a parent of the child, which was one of several positions specifically referenced in section 76-5-404.1(4)(h). The Supreme Court vacated Defendant's conviction and remanded, holding (1) the fact that a defendant occupies one of the positions listed in section 76-5-404.1(4)(h) is insufficient, standing alone, to establish the crime of aggravated sexual abuse of a child; (2) for the State to establish aggravated sexual abuse of a child under subsection 4(h), it must prove both that the defendant occupied a "position of authority" over the victim and that the position gave the defendant the ability to "exercise undue influence" over the victim; and (3) because the lower courts did not require the State to establish both elements, Defendant's conviction must be vacated. View "State v. Watkins" on Justia Law

After a jury trial, Defendant was convicted of aggravated murder, aggravated robbery, and aggravated assault and sentenced to life without parole on the murder conviction. The Supreme Court affirmed, holding (1) Defendant failed to show that the prosecution's decision to charge him with aggravated murder and the district court's denial of his motion to amend the charge to murder violated his constitutional rights; (2) the aggravated murder statute is constitutional; and (3) the admission of victim impact testimony at Defendant's sentencing hearing did not violate constitutional prohibitions against cruel and unusual punishments, and therefore, defense counsel's failure to object to the testimony did not constitute ineffective assistance of counsel. View "State v. Mateos-Martinez" on Justia Law

Susie Stohm, the one-time CFO of ClearOne Communications, was charged with eight federal criminal counts relating to an investigation into certain accounting practices at ClearOne. Strohm was eventually acquitted of all but one count. Strohm and her counsel (Counsel) filed this action against ClearOne, alleging that ClearOne was required to indemnify Strohm for her criminal defense costs. The district court (1) ordered ClearOne to indemnify Strohm for her defense costs subject to certain restrictions, and (2) found that a contract between the parties entitled Counsel to charge ClearOne eighteen percent interests on the amounts that were billed to ClearOne but not timely paid and to collect the costs it expended in enforcing ClearOne's contractual obligation to indemnify Strohm. A unanimous court affirmed the district court affirmed the district court's indemnification decisions in large part, its rulings relating to contract termination rights, its reasonableness determination for fees in the criminal case, and its decision to enforce the eighteen percent interest rate. A majority of the court, however, reversed the district court's decision to allow Counsel to recoup its fees in the collection matter. Remanded. View "Strohm v. ClearOne Commc'ns, Inc." on Justia Law

Defendant was convicted of aggravated assault for stabbing the victim. At trial, the district court instructed the jury on self-defense. However, the court refused to instruct the jury on defense of a third person because it determined that Defendant's theory that he stabbed the victim in defense of a third person was not supported by the evidence. The court of appeals affirmed, concluding that a jury could not reasonably have concluded that the third person was in imminent danger at the time of the assault. The Supreme Court affirmed, holding that there was no basis in the evidence to support Defendant's theory that he acted in defense of the third person when he stabbed the victim. View "State v. Berriel" on Justia Law

Defendant was working as an aide at a middle school when she was convicted of rape, forcible sodomy, and forcible sexual abuse for incidents involving a fifteen-year-old student student and his friend. The trial judge arrested the judgment and granted a new trial on all counts based on evidentiary errors and several irregularities that occurred during trial. The State appealed. The Supreme Court reversed the order granting a new trial and reinstated Defendant's convictions, holding (1) the evidentiary ruling excluding evidence of the victim's sexual predisposition was proper; and (2) the other claimed errors and irregularities did not require reversal because they did not prejudice Defendant. View "State v. Billingsley" on Justia Law

Appellants were defrauded by an individual on parole from a Utah prison. Appellants filed a complaint alleging causes of action against the State for negligent supervision, gross negligence, failure to warn, and negligent misrepresentation. Under the Governmental Immunity Act, the State is immune from a suit where the injury arises out of deceit. The district court dismissed the case based on the State's governmental immunity, finding that Appellants' injury was the result of a third-party's deceit. The Supreme Court affirmed, holding (1) the State was immune under the Utah Governmental Immunity Act's deceit exception; and (2) the dismissal of Appellants' complaint on the basis of governmental immunity was timely. View "Van De Grift v. State" on Justia Law

Defendant pled guilty to disorderly conduct in the justice county and was sentenced to ninety days in jail and ordered to pay a fine. After conducting a trial de novo, the district court convicted Defendant of the original charge, sentenced him to 180 days in jail, and imposed a higher fine. Defendant petitioned the court of appeals for extraordinary relief, arguing that the district court violated Utah Code 76-3-405 when it imposed a more severe punishment than the one originally imposed by the justice court. The court of appeals denied the requested relief, reasoning that although the statute generally prohibits the imposition of a greater sentence after a defendant appeals, Defendant's case fell outside of the general rule because his original conviction and sentence resulted from a plea agreement. The Supreme Court affirmed, holding that the section 76-3-405(2)(b) exception against imposing a harsher sentence on appeal when a defendant has entered into a plea agreement applies to justice court proceedings. View "Vorher v. Court of Appeals" on Justia Law