Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the determination of the Utah State Tax Commission that the Property Tax Division correctly followed the requirements of the Aircraft Valuation Law, Utah Code 59-2-201 subsection 4, in determining the 2017 value of Delta Air Lines' aircraft, holding that Salt Lake County failed to demonstrate that the Law, as applied to Delta's 2017 assessment, violated the fair market value provision of the Utah Constitution.For tax year 2017, the Division valued Delta's aircraft according to section 59-2-201's preferred methodology. The County appealed, arguing that the valuation did not reflect the fair market value of Delta's aircraft, in violation of the Utah Constitution. The Commission upheld the assessment, concluding that the County did not establish that the Legislature's preferred method of valuation did not reasonably reflect fair market value. The Supreme Court affirmed, holding that the Aircraft Valuation Law was not unconstitutional as applied by the Commission to assess the value of Delta's aircraft for tax year 2017. View "Salt Lake County v. Utah State Tax Commission" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion filed under Utah R. Civ. P. 60(b)(6), which allows a court to grant relief from a judgment under certain circumstances, holding that Defendant's challenge to his conviction could have been brought in a petition for post-conviction relief.Defendant pled guilty to two counts of attempted aggravated sexual abuse of a child. Defendant did not file a direct appeal and did not challenge his conviction under Utah's Post-Conviction Remedies Act (PCRA) but later filed a motion under Rule 60(b)(6) alleging ineffective assistance of counsel. The district court denied the motion, ruling that Rule 60(b)(6) was not the appropriate vehicle for Defendant to bring his claim. The Supreme Court affirmed, holding that the PCRA applied to Defendant's request to set aside his conviction based on his trial counsel's alleged conflict of interest. View "State v. Ogden" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of rape, one count of aggravated assault, and two counts of domestic violence in the presence of a child, holding that Defendant was not entitled to relief on his multiple claims of error.Specifically, the Supreme Court held (1) the district court did not abuse its discretion in not withholding from jury deliberations a video exhibit of Defendant's police interview; (2) Defendant failed to show that he was prejudiced by the alleged deficient performance of his trial counsel; and (3) the district court did not err in denying Defendant's motions for a mistrial and a new trial arising out of a child witness's breakdown on the witness stand. View "State v. Centeno" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of aggravated arson, holding that the court of appeals did not err in concluding that Defendant's counsel did not render ineffective assistance.On appeal, Defendant argued that his counsel provided ineffective assistance by failing to move for a directed verdict and by failing to object to the testimony of an expert who opined that the structure Defendant had set fire to was habitable. A divided court of appeals affirmed. The Supreme Court affirmed, holding (1) reasonable counsel could have decided to forgot a motion for directed verdict; and (2) the court of appeals correctly concluded that Defendant was not deprived of the Sixth Amendment guarantees. View "State v. Carter" on Justia Law

The Supreme Court affirmed the judgment of the trial court in this interlocutory appeal of the denial of Defendant's motion to suppress calls made by Defendant on the Salt Lake County Jail's telephones and recorded by the jail, holding that Defendant impliedly consented to the conditions the jail had placed on the use of its phones.Defendant was charged with kidnapping and assaulting his wife and made hundreds of calls to his wife from the jail. The State moved to admit recording of several of those phone calls and filed new charges based on the recordings. Defendant filed a motion to suppress the recordings in both cases. The Supreme Court denied the motions, concluding that Defendant impliedly consented to the interception of the phone calls and that the calls were exempt under the law enforcement exception to Utah's Interception of Communications Act, Utah Code 77-23a-1 to -16. The Supreme Court affirmed, holding that Defendant impliedly consented to the jail's recording of his phone calls, and therefore, the interception of Defendant's calls was authorized under the Interception Act's consent exception. View "State v. Wood" on Justia Law

In this action brought by Utah Stream Access Coalition (USAC) after USAC members were cited for trespass for wading in the Provo River on property owned by VR Acquisitions the Supreme Court held that the district court correctly entered judgment against USAC.In its complaint, USAC claimed that the Public Waters Access Act (PWAA) violated Utah Const. art. XVII and XX and federal common law. The district court entered summary judgment against USAC on its article XVII and federal common law claims but, after a bench trial, determined that the PWAA violated article XX. On appeal, the Supreme Court determined that the district court made a threshold error in reaching its article XX determination and remanded with instruction that the court address the threshold question of whether the easement identified in Conaster v. Johnson, 194 P.3d 897 (Utah 2008), had a historical basis as a public easement at the time the Utah Constitution was framed. On remand, the district court granted summary judgment for VR Acquisitions and the State. The Supreme Court affirmed, holding that because USAC did not identify an affirmative, 19th-century legal basis for a Conaster easement, the district court correctly ruled that USAC did not make the threshold showing. View "Utah Stream Access Coalition v. VR Acquisitions, LLC" on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying Defendant's motion for remand under rule 23B of the Utah Rules of Appellate Procedure after a jury convicted him of aggravated robbery, holding that the court of appeals did not err.On appeal of his conviction, Defendant alleged that his trial counsel was ineffective by not supporting his mistaken identity defense with evidence that Defendant had prominent tattoos on his hands that were not visible in surveillance images of the robber. Defendant moved under rule 23B to supplement the record with facts concerning his trial counsel's alleged ineffective assistance. The court of appeals denied Defendant's rule 23B motion. The Supreme Court affirmed, holding (1) Defendant's rule 23B motion did not allege that the arresting officers would provide favorable testimony; and (2) therefore, Defendant failed to offer nonspeculative facts that, if true, would have established that he was prejudiced by his counsel's failure to question the officers about Defendant's tattoos or comment on that evidence in closing argument. View "State v. Samora" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating Defendant's convictions based on ineffective assistance of counsel, holding that errors in the proceedings below did not prejudice Defendant.In vacating Defendant's convictions the court of appeals concluded that trial counsel had been ineffective by failing to object to introduction and use of evidence about Defendant's silence while being arrested and by not objecting to the manslaughter jury instruction. The court ultimately concluded that Defendant was prejudiced by these instances of deficient performance. The Supreme Court reversed and reinstated the convictions vacated by the court of appeals, holding (1) trial counsel performed deficiently in failing to object to a certain jury instruction; and (2) assuming counsel was also deficient for not objecting to the State's use of Defendant's post-arrest, pre-Miranda silence against Defendant, Defendant failed to establish that there was a reasonable probability that the outcome of the trial would have been different without these errors. View "State v. Bonds" on Justia Law

The Supreme Court remanded this case in which the district court prohibited Father from encouraging his children to adopt the teachings of any religion without Mother's consent, holding that Father had a fundamental right to encourage his children in the practice of religion and that the district court's prohibition was not narrowly tailored to address the harms identified by the court.When they married, Father and Mother were both members of the Order, a polygamous religious community. Based on the parties' inability to agree on decisions regarding their four children, the district court granted sole legal custody to Mother and prohibited Father from encouraging the children to adopt the teachings of any religion. The Supreme Court remanded this case to the district court, holding (1) parents have a fundamental right to encourage their children in the practice of religion, and this right is not dependent upon legal custody; (2) strict scrutiny applies to this case; and (3) the district court's prohibition is not narrowly tailored to address the identified harms. View "Kingston v. Kingston" on Justia Law

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