Justia Civil Rights Opinion Summaries

Defendant pled guilty to disorderly conduct in the justice county and was sentenced to ninety days in jail and ordered to pay a fine. After conducting a trial de novo, the district court convicted Defendant of the original charge, sentenced him to 180 days in jail, and imposed a higher fine. Defendant petitioned the court of appeals for extraordinary relief, arguing that the district court violated Utah Code 76-3-405 when it imposed a more severe punishment than the one originally imposed by the justice court. The court of appeals denied the requested relief, reasoning that although the statute generally prohibits the imposition of a greater sentence after a defendant appeals, Defendant's case fell outside of the general rule because his original conviction and sentence resulted from a plea agreement. The Supreme Court affirmed, holding that the section 76-3-405(2)(b) exception against imposing a harsher sentence on appeal when a defendant has entered into a plea agreement applies to justice court proceedings. View "Vorher v. Court of Appeals" on Justia Law

The Utah Highway Patrol performed a drug interdiction exercise on a rural stretch of the interstate. UHP chose to focus the bulk of its enforcement efforts on cars bearing out-of-state license plates. Defendant's California-plated vehicle was stopped during the exercise, and the traffic stop yielded evidence of illegal drugs. Defendant was charged with possession with intent to distribute. Defendant filed two suppression motions - one based on the Equal Protection Clause and right to travel and the other rooted in the Fourth Amendment. The district court denied both motions, and Defendant entered a conditional guilty plea. On appeal, the Supreme Court affirmed, holding (1) the traffic stop did not restrict Defendant's movement in a manner implicating his fundamental right to travel; (2) because there was a rational basis for UHP's selective enforcement of traffic laws - by choosing to stop vehicles licensed outside of Utah - Defendant's equal protection claim was meritless; and (3) to the extent the district court erred in failing to consider any evidence of relevance to the Fourth Amendment motion to suppress, it was harmless error. View "State v. Chettero" on Justia Law

Defendant, a passenger in a vehicle stopped for a traffic infraction, was arrested for possession of methamphetamine after being questioned and searched by a deputy sheriff. Defendant moved to suppress the fruits of the search. The district court denied the motion to suppress, and the court of appeals affirmed. Defendant appealed, arguing that the deputy improperly extended the length of the detention without reasonable suspicion that Defendant was engaged in criminal activity. The Supreme Court affirmed, holding (1) the deputy's questioning of Defendant, during which Defendant admitted to possession of illegal drugs, was proper based on the deputy's reasonable suspicion brought about by the driver's likely impairment and the presence of used drug paraphernalia in plain sight; and (2) the deputy did not improperly extend the duration of Defendant's detention because the deputy's single question to Defendant resulted in only a de minimis extension of the otherwise lawful detention. View "State v. Simons" on Justia Law

Defendant as convicted of aggravated murder and attempted aggravated murder. Defendant's conviction was affirmed on appeal, after which he filed a pro se petition seeking relief under the Post-Conviction Remedies act (PCRA) on the grounds that his trial counsel was ineffective for failing to raise a defense and that his appellate counsel was ineffective for failing to raise a claim of ineffective assistance of counsel on direct appeal. The court granted summary judgment for the State, concluding that Defendant's appellate counsel was not ineffective and that Defendant's ineffective assistance of trial counsel claim was procedurally barred. The Supreme Court reversed, holding (1) disputed issues of material fact precluded summary judgment on Defendant's claim that his appellate counsel was ineffective; and (2) because the Court could not determine whether appellate counsel was ineffective, it could not determine whether Defendant's claim regarding trial counsel was procedurally barred by the PRCA. Remanded for an evidentiary hearing. View "Ross v. State" on Justia Law

After a jury trial, Petitioner was convicted of four counts of sodomy on a child and one count of sexual abuse of a child. The convictions were affirmed on direct appeal. Approximately a dozen years later, Petitioner filed a petition for post-conviction relief. The district court dismissed the petition as procedurally barred under the Post-Conviction Remedies Act's one-year statute of limitations. Petitioner appealed, arguing that applying the one-year statute of limitations to his petition violated the Utah Constitution under the "egregious injustice" exception set forth in Gardner v. State. The Supreme Court (1) affirmed the district court's dismissal of all but one of the claims alleged in Petitioner's petition; but (2) vacated the district court's dismissal of Petitioner's claim for ineffective assistance of counsel during the plea bargaining process, as Defendant may have a newly-recognized claim under the recent U.S. Supreme Court decision, Lafler v. Cooper, which could extend the statute of limitations on his claim. Remanded. View "Winward v. State" on Justia Law

A jury convicted Petitioner of aggravated sexual abuse of a child, sodomy on a child, and attempted rape of a child. The court of appeals affirmed. On certiorari, Petitioner argued that the court of appeals erred in affirming the trial court's ruling that the state was not required to make a separate showing of good cause to admit the alleged victim's recorded statements under Utah R. Crim. P. 15.5. The Supreme Court affirmed the court of appeals, holding (1) a separate showing of good cause to admit a recorded statement is not required under rule 15.5; and (2) rather, good cause is established when the trial court considers all the factors in the rule and determines that the recorded statement is accurate, reliable, and trustworthy, and that admission of the recorded statement is in the interest of justice. View "State v. Nguyen" on Justia Law

Appellant, the biological father of Baby Girl T., challenged the district court's determination of his rights as a birth father and its grant of a motion in limine preventing his presentation of evidence. The court concluded that Appellant did not comply with the provisions of the Utah Adoption Act and therefore waived the right to notice of any judicial proceeding in connection with the adoption of Baby Girl T., as well as the right to refuse to consent to her adoption. It also barred Appellant from presenting evidence that the reason he failed to comply with requirements of the Act was because state employees negligently failed to register his notice of paternity proceedings prior to the birth mother's execution of a consent to adoption. The Supreme Court reversed and remanded, holding that the Act was constitutionally defective as applied to Appellant and deprived him of a meaningful chance to preserve his opportunity to develop a relationship with his child. View "In re Baby Girl T" on Justia Law

Defendant was charged with two counts of assault. He appeared for a jury trial and was subsequently convicted of a misdemeanor assault. Defendant appealed, claiming that his jury was assembled in a manner inconsistent with the requirements of the Equal Protection Clause. The Supreme Court disagreed and affirmed, holding (1) Defendant failed to timely preserve his Batson challenge, (2) the trial court did not err when it did not make findings or rule on the Batson challenge, and (3) Defendant's ineffective assistance of counsel claim based on his counsel's failure to timely preserve his Batson challenge failed under Washington v. Strickland. View "State v. Harris" on Justia Law

Defendant entered into a plea agreement in 2005 in which the State promised to not oppose a motion to reduce his convictions. Defendant later filed a motion to reduce his convictions after successfully completing his probation, as required by statute. During his probation, however, the statute governing reduction of convictions was amended to bar reduction for crimes like Defendant's that triggered the sex offender registration requirement. The district court applied the amended statute retroactively to deny Defendant's motion. The Supreme Court reversed and remanded for reconsideration of Defendant's motion under the version of the statute in effect when he was initially sentenced, holding that the district court erred in applying the amended statute to Defendant's motion to reduce his convictions. View "State v. Johnson" on Justia Law

In 1985, Appellant was convicted of first degree murder and sentenced to death. In 2006, Appellant filed a successive postconviction petition for relief. In 2009, the district court dismissed Appellant's petition, holding (1) all claims were procedurally barred except the claim of ineffective assistance of postconviction counsel in the first Post Conviction Relief Act (PCRA) proceedings; and (2) Appellant's ineffective assistance of counsel claim was not timely brought. The Supreme Court affirmed the dismissal, holding (1) the district court did not abuse its discretion in denying Appellant's request for a six-month stay of proceedings; (2) the district court was correct in determining that all of Appellant's claims were procedurally barred except the claim of ineffective assistance of postconviction counsel; and (3) because Appellant did not make a showing of ineffective assistance, the Court did not need to consider whether the claim was time barred or whether Appellant had either a statutory or constitutional right to effective assistance of postconviction counsel. View "Carter v. State" on Justia Law