Justia Criminal Law Opinion Summaries

The Supreme Court vacated Defendant's conviction of child abuse and remanded the case to the district court to enter findings about whether the punishment that Defendant gave his son was "reasonable discipline."Defendant spanked his son with enough force to leave bruises in the shape of a handprint on the child's bottom that were visible two days later. Defendant was charged with child abuse under Utah Code 76-5-109(3)(c). The court of appeals affirmed. The Supreme Court vacated the conviction and remanded the case for further proceedings, holding that the court of appeals erred in determining that it was "clear from the record" that the district court correctly applied and analyzed the statute's "reasonable discipline" provision. View "Bountiful City v. Baize" on Justia Law

The Supreme Court reversed the judgment of the district court denying the State's motion in limine to admit unsworn statements witnesses made to officers shortly after the shooting in which they defined Defendant as the person who fired the shots, holding that the district court erred.After the two witnesses identified Defendant as the gunman they later recanted. The State sought to call the witnesses to testify and to impeach them with their first version of their story. The district court entered an order preventing the State from calling the witnesses, concluding that it would be improper to allow the prior inconsistent statements to come before the jury. The Supreme Court reversed, holding that the district court misinterpreted the Utah Rules of Evidence and that nothing in the rules prohibits the State from calling witnesses to give potentially unhelpful testimony if the State plans to impeach the witness with her helpful prior inconsistent statements. View "State v. Biel" on Justia Law

The Supreme Court reversed the judgment of the district court denying Alexie Kamoe's petition for extraordinary relief, holding that an appeal from a negotiated plea in justice court under Utah Code 78A-7-118(3) does not vacate that court's judgment.Kamoe was charged in justice court with three separate criminal counts. Pursuant to a plea agreement, Kamoe pled guilty to a single count of impaired driving. Kamoe appealed to district court but withdrew the appeal after the denial of her motion to suppress blood-test evidence. Kamoe then returned to justice court seeking to have her original conviction, sentence, and commitment reinstated. The prosecutor, who wanted Kamoe to face trial on the initial three counts, objected. The justice court denied Kamoe's request for reinstatement. Kamoe then filed a petition for extraordinary relief under Utah R. Civ. P. 65B(d)(2). The district court denied the petition. The Supreme Court reversed and remanded the case to the justice court with instructions to reinstate Kamoe's original judgment, holding that a criminal defendant's appeal of a guilty plea made in justice court does not void that court's conviction, sentence and commitment. View "Kamoe v. Honorable Stevan Ridge" on Justia Law

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