Justia Criminal Law Opinion Summaries

The Supreme Court reversed the decision of the court of appeals vacating Defendant's convictions on the grounds that his counsel had been ineffective, holding that errors on the part of trial counsel did not prejudice Defendant.Defendant was convicted of murder and several related charges. The court of appeals vacated the convictions, determining that trial counsel was ineffective in failing to object to the use of evidence about Defendant's silence while being arrested and in not objecting to the manslaughter jury instruction, prejudicing Defendant. The Supreme Court reversed, holding (1) defense counsel was ineffective for not objecting to the manslaughter jury instruction, which incorrectly shifted the burden of proof for imperfect self-defense, but the error was not prejudicial; and (2) assuming that defense counsel was ineffective for failing to object to commentary by the prosecution in Defendant's silence after arrest, the error was not prejudicial. View "State v. Bonds" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that the conduct of two court personnel while sharing a nonpublic courthouse elevator with a jury during trial triggered a rebuttable presumption of prejudice against Defendant, holding that the court of appeals did not err.The court personnel in this case - a uniformed highway patrolman and a court IT technician - told the jurors, in so many words, to find Defendant guilty and to "hang him." The trial court bailiff also stood in the elevator but did not intervene in the exchange. The court of appeals reversed Defendant's conviction and remanded the case for a new trial. The Supreme Court affirmed, holding that the impermissible contact violated Defendant's right to an impartial jury and triggered a rebuttable presumption that Defendant was prejudiced as a result. The Court remanded the case to the district court for a determination of whether the State met its burden to rebut this presumption. View "State v. Soto" on Justia Law

After exiting his brother’s truck at a busy intersection, Pierce fatally shot Toala. After receiving his Miranda warnings, Pierce claimed that he acted in self-defense. His statement was later suppressed. There were multiple witnesses, who disagreed about whether Toala was aggressive or threatening toward Pierce. The Utah Supreme Court affirmed Pierce’s conviction for manslaughter by imperfect self-defense as supported by sufficient evidence. The court rejected an argument that the trial court committed plain error by failing to “sua sponte” cut off the prosecution’s questions and comments about the differences between Pierce’s trial testimony and what he told the police. The law concerning any error was not clear at the time of trial. View "State v. Pierce" on Justia Law

The Supreme Court held in this interlocutory appeal that the district court may not judge the sufficiency of the defendant's showing necessary to overcome a motion to quash based solely on an in camera proffer without first affording the State an opportunity to respond.Defendant was charged with seven felony charges for an alleged pattern of sexual abuse in connection with A.W. over the course of several years while Defendant was A.W.'s pastor. Defendant denied the charges and served A.W. with a subpoena to appear and testify at his preliminary hearing. A.W. moved to quash the subpoena. Defendant moved to make the showing necessary to overcome the motion to quash in camera and only in the district court. The district court granted the motion. The Supreme Court reversed, holding that Defendant must make his proffer under State v. Lopez, 474 P.3d 949 (Utah 2020), in open court, giving the State an opportunity to respond. View "State v. Archibeque" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant's motion brought under Utah R. Civ. P. 70(b) or, alternatively, as a motion for a misplea, arguing that the prosecution breached the parties' plea agreement, holding that Appellant's constitutional challenge to his guilty plea was properly considered only under the Post-Conviction Remedies Act (PCRA).Appellant was charged with aggravated murder and other counts related to making and transporting a bomb. Pursuant to a plea agreement, Appellant pled guilty to depraved indifference murder. Twenty-three years later, Appellant brought this motion, arguing that there was no other available avenue for relief. The district court dismissed the motion. The Supreme Court affirmed, holding that Appellant's claim should have been brought under the PCRA. View "State v. Thurman" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction and the denial of his motion to suppress, holding that the State did not meet its burden in rebutting a presumptively unreasonable seizure.The police found Defendant sleeping in his car in a McDonald's parking lot. The officers asked Defendant to exist his vehicle and ordered him to perform a field sobriety test. Defendant was subsequently charged with driving under the influence of alcohol. Defendant moved to suppress evidence and statements as a result of his seizure, arguing that his seizure and subsequent searches were unlawful. The district court denied the motion, concluding that Defendant's seizure was justified by the community caretaking doctrine. The Supreme Court reversed, holding that the State did not meet is burden to rebut the presumption of unreasonableness. View "State v. Smith" on Justia Law

The Supreme Court affirmed the ruling of the district court convicting Defendant of aggravated battery and denying Defendant's motion for a directed verdict, holding that the evidence was sufficient to support the conviction.A jury convicted Defendant of aggravated robbery. Defendant appealed, arguing that a 911 call was inadmissible hearsay and that its admission at trial was prejudicial error. The Supreme Court affirmed, holding (1) the district court properly admitted the 911 call under the present sense impression exception to the rule against hearsay; and (2) this Court declines to reexamine caselaw requiring criminal appellants to show prejudice from preserved errors. View "State v. Johnson" on Justia Law

The Supreme Court held that the court of appeals correctly held that the conduct of two court personnel triggered a rebuttable presumption against Defendant, holding that remand was required.The court personnel in this case shared a nonpublic courthouse elevator with a jury during Defendant's trial and either told the jurors to find Defendant guilty and "hang him" or stood quietly in the elevator. On appeal, Defendant argued that the improper juror contact denied him his constitutional right to a fair trial and impartial jury. The court of appeals agreed and reversed Defendant's conviction and remanded the case for a new trial. The Supreme Court affirmed, holding (1) the improper contact violated Defendant's right to an impartial jury and triggered a rebuttable presumption that Defendant was prejudiced by the constitutional error; and (2) the case must be remanded for a determination as to whether the State had met its burden. View "State v. Soto" on Justia Law

In this case involving to multiple prosecutions of Defendant for the robbery and theft of a used car the Supreme Court affirmed the judgment of the court of appeals dismissing a subsequent charge against Defendant for aggravated robbery in Weber County, holding that all provisions under Utah's Single Criminal Episode Statute, Utah Code 76-1-401 to -403, were met.The State prosecuted Defendant in Weber County for aggravated robbery after he had already been convicted of theft by receiving in Utah County for conduct arising under the same criminal episode. After the court of appeals dismissed the Weber County charge the State appealed, arguing that Defendant's convictions were not part of a single criminal episode and that the Single Criminal Episode Statute did not apply because the district court in Utah County did not have jurisdiction to hear both offenses. The Supreme Court affirmed, holding that the conviction of Defendant in Utah County for theft by receiving barred the State's subsequent prosecution of Defendant in Weber County for aggravated robbery. View "State v. Sisneros" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction on a misdemeanor charge of threatening to use a dangerous weapon in a quarrel with his father, holding that Defendant identified no basis for reversal.The district court concluded that Defendant's "use or threat of the weapon under the circumstances was not necessary or reasonable" and found him guilty as charged. The court of appeals affirmed. Defendant appealed, arguing that the court of appeals erred in affirming the conviction under an "objective standard of reasonableness." The Supreme Court affirmed, holding (1) Defendant did not establish that the court of appeals adopted a standard of reasonableness that differed from the one articulated in this opinion; and (2) Defendant failed to show that there was error in the application of the statutory standard in the district court. View "State v. Sorbonne" on Justia Law