Justia Civil Rights Opinion Summaries

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

The Utah Department of Transportation (UDOT) owned a piece of property on land adjacent to property owned by Plaintiff. Plaintiff filed a condemnation action, asserting a right to condemn a portion of UDOT's parcel to construct an access road to the development Plaintiff planned to build on its property. The district court granted summary judgment for UDOT, finding that the two parties' uses were incompatible because the detention pond on UDOT's property left no room for Schroeder's proposed road. Plaintiff appealed, challenging the district court's invocation of the more necessary public use doctrine and its refusal to allow an exception under the doctrine of compatible uses. The Supreme Court affirmed, holding that, absent any basis for a compatible use exception in this case, UDOT was entitled to judgment as a matter of law. View "Schroeder Invs., L.C. v. Edwards" 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

In 2006, the Central Utah Water Conservancy District (District) filed an action to condemn six waterfront lots owned by Petitioner. When negotiations reached an impasse on the value of the lots, the District instituted the underlying condemnation proceeding. The jury returned a verdict for Petitioner in the amount of $56,000. Petitioner filed a motion for a new trial, which the district court denied. Petitioner filed an appeal less than thirty days after the entry of the district court's ruling and order. The court of appeals dismissed Petitioner's appeal without prejudice based upon lack of jurisdiction, holding that under Utah R. Civ. P. 7(f)(2) and the Supreme Court's decision in Giusti v. Sterling Wentworth Corp., Petitioner's appeal was not ripe because it was not taken from a final, appealable order. The Supreme Court affirmed, holding that under Rule 7(f)(2), Petitioner's appeal was premature and that the court of appeals therefore correctly dismissed it without prejudice. View "Central Utah Water Conservancy Dist. v. King" 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

At issue in this case were two agreements: a ground lease agreement between ASC Utah, Inc. (ASCU) and Wolf Mountain Resorts, and a specifically planned area (SPA) development agreement, which had thirty-six signatories, including ASCU, Wolf Mountain, the D.A. Osguthorpe Family Partnership (Osguthorpe). ASCU and Wolf Mountain began litigating claims involving both the ground lease and the SPA agreement. Shortly thereafter, Osguthorpe sued ASCU and Wolf Mountain, alleging that each party had breached a land-lease agreement distinct from the ground lease or the SPA agreement. The district court consolidated Osguthorpe's separate actions into ASCU's litigation. Osguthorpe later moved to compel arbitration on all the claims related to the SPA agreement, including the claims between ASCU and Wolf Mountain, to which Osguthrope was not a party. The district court denied Osguthrope's motion. Osguthrope withdrew its SPA claims from the case, leaving for appeal only Osguthrope's motion to compel arbitration of the SPA claims between ASCU and Wolf Mountain. The Supreme Court affirmed, holding (1) the disputes for which Osguthrope sought to compel arbitration were not subject to the SPA agreement's arbitration provision; and (2) furthermore, as a non-party to the disputes, Osguthrope had no contractual right to compel their arbitration. View "Osguthorpe v. Wolf Mountain Resorts, L.C." on Justia Law