Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of felony driving under the influence (DUI) and possession of drugs and drug paraphernalia, holding that the exclusionary rule does not apply where law enforcement relied reasonably on then-existing precedent.In affirming Defendant's conviction, the court of appeals held that the police had the reasonable suspicion necessary to temporarily detain Defendant in his vehicle and ask him to step out of it. The Supreme Court affirmed, holding (1) this Court repudiates the sweeping language of its opinion in State v. James, 13 P.3d 576 (Utah 2019), and holds that the identity of the opener of a car door may affect the reasonableness of any given police encounter; but (2) the evidence here was not subject to exclusion because the police acted objectively reasonably in reliance on the Supreme Court's opinion in James. View "State v. Malloy" on Justia Law

The Supreme Court affirmed on all but one issue the judgment of the court of appeals affirming Defendant's convictions for violation of a protective order, three counts of aggravated sexual assault, kidnapping, burglary, and assault, holding that the district court erred by not instructing the jury on sexual battery as a lesser included offense of the aggravated sexual assault charge based on forcible sexual abuse.Specifically, the Supreme Court held (1) any error in the jury instructions for aggravated sexual assault and the underlying offenses of rape and forcible sexual abuse were not prejudicial; (2) the district court did not err by not instructing the jury on any of the lesser included offenses Defendant requested, except for sexual battery; and (3) at sentencing, the district court did not err in imposing a punishment of fifteen years to life for aggravated sexual assault. View "State v. Norton" on Justia Law

The Supreme Court vacated Defendant's conviction on the offense of domestic violence in the presence of a child, holding that a jury could not both convict Defendant of the compound offense of domestic violence in the presence of a child and acquit him of the predicate offense of domestic violence assault.Pleasant Grove City charged Defendant with one count of domestic violence assault and one count of commission of domestic violence in the presence of a child. A jury convicted Defendant on the offense of commission of domestic violence in the presence of a child but acquitted him of the offense that predicated the conviction - domestic violence assault. The trial judge did not intervene in the verdict. The Supreme Court vacated the conviction, holding that the verdict in this case was legally impossible and that vacatur of the verdict was required. View "Pleasant Grove City v. Terry" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated sexual abuse, holding that the district court did not err in concluding that there was sufficient evidence to sustain Defendant's convictions.On appeal, Defendant argued that the district court erred by denying his motion for a directed verdict and a motion to arrest judgment. Specifically, Defendant argued that the State presented insufficient evidence to convict him because the victim recanted her story that Defendant had inappropriately touched her. The Supreme Court affirmed, holding that the jury was entitled to weigh the two versions of the victim's story, consider the other evidence of Defendant's guilt, and decide which version of the victim's story it found to be credible. View "State v. Stricklan" on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated robbery, holding that the trial court did not plainly err in its handling of the State's reports of a sleeping juror and that defense counsel did not provide ineffective assistance.On appeal, Defendant asserted that he was denied his Sixth Amendment right to a jury trial because at least one juror allegedly slept during the proceedings. The court of appeals concluded that Defendant failed to demonstrate that the trial court plainly erred in declining to inquire into the attentiveness of the juror and that Defendant failed to demonstrate that his trial counsel provided ineffective assistance in responding to observations that the juror may have been sleeping. The Supreme Court affirmed, holding (1) a trial court should respond to a report of an inattentive or drowsy juror in a manner that is proportional to the report before it, but the trial court in this case did not plainly err in its response; and (2) Defendant failed to show that his counsel's actions were deficient. View "State v. Marquina" on Justia Law

The Supreme Court affirmed the post-conviction court's grant of summary judgment against Defendant's post-conviction claims, holding that Defendant's Atkins v. Virginia, 536 U.S. 304 (2002), claim was not cognizable under the Post-Conviction Remedies Act (PCRA).Defendant was convicted of first-degree murder and sentenced to death. Later, Defendant filed a third state petition for post-conviction relief, including an Atkins claim and twelve additional claims unrelated to Atkins. The post-conviction court concluded that all of Defendant's claims were barred under the PCRA. The Supreme Court affirmed, holding (1) the PCRA did not provide a remedy for Defendant's Atkins claim; and (2) each of Defendant's remaining claims was procedurally barred. View "Archuleta v. State" on Justia Law

The Supreme Court held that any power a defendant has to subpoena witnesses at a preliminary hearing is limited by the court's authority to quash unreasonable subpoenas, and that reasonableness inquiry must be informed by the standards that govern preliminary hearings and the rights that the law guarantees for crime victims.The two defendants in this consolidated opinion sought to compel their alleged victims to testify by way of subpoena. The victims, however, had previously participated in interviews about their alleged abuse, and those interviews were introduced as reliable hearsay at the defendants' preliminary hearings. The Supreme Court held that once the State has used a victim's reliable hearsay to make a prima facie showing of probable cause, a subpoena compelling the victim to give additional, live testimony will survive a motion to quash only if the defendant demonstrates that the subpoena is necessary to present specific evidence that is reasonably likely to defeat the showing of probable cause. View "State v. Lopez" on Justia Law

The Supreme Court affirmed Defendant's sentence of life in prison without the possibility of parole for aggravated murder, holding that Defendant was not entitled to a new penalty-phase trial.Specifically, the Supreme Court held (1) even if Defendant's trial counsel rendered ineffective assistance, Defendant was not prejudiced by that deficiency; (2) any error in admitting certain hearsay statements during trial was harmless beyond a reasonable doubt; (3) Defendant was not prejudiced by victim-impact evidence; (4) the trial court did not abuse its discretion by refusing to give a beyond-a-reasonable-doubt jury instruction under State v. Lafferty, 749 P.2d 1239 (Utah 1988); and (5) Defendant inadequately briefed his argument under the doctrine of cumulative error. View "State v. Drommond" on Justia Law

In this criminal case, the Supreme Court reversed the ruling of the court of appeals that the trial court erred in admitting the testimony of the State's expert witness, holding that the court of appeals conflated the requirements and remedies of the Expert Notice Statute, Utah Code 77-17-13, and Utah R. Evid. 702 and in shifting the burden to the State to disprove prejudice.The court of appeals vacated Defendant's convictions of four counts of sodomy on a trial, holding (1) the trial court committed reversible error in allowing the State's expert witness to testify in violation of Rule 702; and (2) the State did not meet its burden to prove that Defendant had not been prejudiced by the denial of his motion for a continuance. The Supreme Court reversed, holding (1) the court of appeals' Rule 702 analysis was erroneous; and (2) the court of appeals erred in shifting the burden to the State to disprove prejudice. View "State v. Peraza" on Justia Law

The Supreme Court largely affirmed the decision of the court of appeals affirming Defendant's convictions of violating a protective order, aggravated sexual assault relating to rape and digital penetration, kidnapping, burglary, and assault but held that the district court erred in refusing to instruct on sexual battery as a lesser included offense of aggravated sexual assault based on forcible sexual abuse.Specifically, the Supreme Court held that the court of appeals (1) did not err in concluding that any error in the jury instructions on aggravated sexual assault, rape, and forcible sexual abuse did not prejudice Defendant; (2) did not err in affirming the district court's refusal to instruct the jury on additional lesser included offenses of aggravated sexual assault based on rape, aggravated burglary, and aggravated kidnapping but erred in affirming the district court's refusal to instruct on sexual battery as a lesser included offense of aggravated sexual assault based on forcible sexual abuse; (3) did not err in affirming the district court’s sentence of fifteen years to life on both convictions of aggravated sexual assault; (4) did not err in concluding that the district court conducted a proper interests of justice analysis at sentencing; and (5) did not err in rejecting Norton’s claim of cumulative error.` View "State v. Norton" on Justia Law