Justia Civil Rights Opinion Summaries

Tina Harding was one of three passengers in a vehicle that was stopped by a law enforcement officer. The driver gave the officer her consent to search the vehicle. Without inquiring about who owned them, the officer proceeded to search two backpacks and bags found in the vehicle. The officer found drugs and paraphernalia in the backpacks, which belonged to Harding. Harding subsequently entered a conditional guilty plea to methamphetamine possession and possession of a dangerous weapon by a restricted person. The court of appeals affirmed. Harding appealed, asserting that the officer had improperly assumed the driver had authority to consent to the search of her backpacks. The Supreme Court concluded (1) the evidence adduced in the district court supported the conclusion that the officer could not have reasonably believed that the driver had authority to consent to a search of Harding's backpacks; but (2) the district court did not make any particularized findings as to whether Harding's conduct in relation to the search suggested the driver had apparent authority to consent to a search of her backpacks or as to the general nature of the backpacks searched by the officer. Remanded for further factual findings.

The State filed a delinquency petition alleging that a seventeen-year-old girl had engaged in criminal solicitation to commit murder after she asked a stranger to punch her in the stomach to terminate her pregnancy. The juvenile court (1) held that an assault of a woman by punching her in the stomach was a "procedure" intended to terminate her pregnancy and therefore qualified as an abortion under statute; and (2) dismissed the State's petition against the minor because a woman cannot be held criminally liable for seeking an abortion. The Supreme Court reversed, holding that the solicited assault of a woman to terminate her pregnancy was not a "procedure" as contemplated by statute and therefore did not constitute an abortion. Remanded.

Defendant pleaded guilty to attempted murder of the unborn child of a juvenile mother. The charge and plea were based on the allegation that Defendant tried to kill the child by punching Mother in the abdomen in exchange for a payment by Mother. At Defendant's sentencing, the district court sua sponte found him ineligible for conviction of attempted murder under the standard set forth in State v. Shondel and sentenced him instead to the lesser charge of attempted killing an unborn child by abortion. The Supreme Court reversed, holding (1) the State had a statutory right of appeal from the district court's holding because the court implemented the decision to effect a "final judgment of dismissal" of the murder charge; (2) the Court's reconsideration of the district court's decision did not raise double jeopardy concerns because a reversal would not subject Defendant to successive prosecution but merely reinstate Defendant's guilty plea on the attempted murder charge; and (3) there was no Shondel bar to Defendant's sentencing on the charge of attempted murder because the elements of attempted murder differ from the elements of attempted killing of an unborn child by abortion.

Michael Archuleta was convicted of first degree murder and sentenced to death. This opinion consolidated analysis from the fourth and fifth times the Supreme Court entertained appeals by Archuleta. The Supreme Court reaffirmed Archuleta's conviction and sentence, holding (1) the habeas court properly found that Archuleta's substantive challenges to his conviction and sentence were procedurally barred, and the habeas court correctly determined that Archuleta could not demonstrate his counsel rendered ineffective assistance under Strickland v. Washington; and (2) the district court did not abuse its discretion in denying Archuleta's Utah R. Civ. P. 60(b) motion because (i) Archuleta's rule 60(b)(1) motion was time-barred, and (ii) rule 60(b)(6)'s provision stating that judgment will be set aside for "any other reason justifying relief from the operation of the judgment" applies only in extraordinary circumstances not presented in this case.

Terry Johnson was convicted of murdering his child's babysitter. The court of appeals affirmed. Johnson subsequently filed a petition for postconviction relief, challenging, among other things, his counsel's effectiveness and the sufficiency of the evidence supporting his conviction. The district court denied the petition without reaching the merits of Johnson's claims, finding each claim was either previously adjudicated, frivolous, or barred under the Post-Conviction Remedies Act. The Supreme Court affirmed, holding that because Johnson's petition contained claims that had been previously adjudicated, that the district court had no jurisdiction to decide, and that could have been, but were not, raised on direct appeal, the district court correctly dismissed Johnson's petition.

Three cases, including State v. Davis, State v. Jeffs, 2011 UT 56, and State v. Parduhn, 2011 UT 55, were consolidated in this opinion. All three cases came to the Supreme Court on interlocutory appeal and involved nearly identical facts and issues. Each Defendant was charged with crimes in Salt Lake County. Although each Defendant qualified for representation by a public defender, each Defendant retained a private attorney. Subsequently, each Defendant filed a motion requesting funding for expert witnesses and other defense resources, which the district court denied. The Supreme Court reversed, holding (1) the holding in State v. Burns, which states that the Utah Indigent Defense Act requires local governments to provide indigent defendants with funding for necessary defense resources even when the defendant is represented by private counsel, remains good law after amendments to the Act; and (2) because the Act requires a defendant to demonstrate a compelling reason to receive funding for defense resources only when a local government has contracted to provide such resources to all indigent defendants, and the County in this case had not so contracted, the district court erred in requiring Defendants to demonstrate a compelling reason for the requested funding.

Judge Judith Atherton presided over a criminal proceeding involving an indigent defendant in which Atherton ordered the Salt Lake Legal Defender Association (LDA) to provide funding for the defendant's expert. LDA was not given notice of the hearing on the defendant's motion requesting funding for his expert witness and was not present at the hearing. LDA filed a petition for extraordinary relief. The Supreme Court granted the petition and vacated Atherton's order, holding that Atherton violated LDA's right to due process by ordering LDA to provide funding for the defendant's expert witness without giving it notice or an opportunity to be heard. Remanded.

Chanzy Walker was involved in an accident that killed one person. The detectives investigating the incident obtained a warrant from a magistrate judge to draw and test Walker's blood. A blood sample from Walker revealed the presence of methamphetamine and amphetamine. After the State charged Walker with several offenses, Walker filed a motion to suppress the results of the blood test. At a pretrial hearing, The district court concluded that the warrant lacked probable cause. Despite this conclusion, the district court denied the motion to suppress based on its determination that the good faith exception to the exclusionary rule applied in this case. Walker later entered a conditional plea to causing the death of another by operating a motor vehicle in a negligent matter with a controlled substance in the body and possessing a controlled substance. The Supreme Court affirmed the district court's denial of Walker's motion to suppress, holding that the magistrate had a substantial basis to believe that evidence of illegal conduct would be found in Walker's blood and, therefore, the warrant was supported by probable cause.

Douglas Lovell pleaded guilty to aggravated murder. Lovell subsequently moved to withdraw his plea. The district court initially held that Lovell's motion was untimely, but the Supreme Court reversed and remanded for consideration of the merits of Lovell's motion. In district court, Lovell argued he had good cause to withdraw his plea because the trial court failed to strictly comply with Utah R. Crim. P. 11(e), which sets out the requirements for a lawful guilty plea. The district court held that the trial court complied with rule 11(e) and that, even if it did not, the error did not amount to good cause to allow Lovell to withdraw his plea because Lovell did not show that but for the error he would not have pled guilty. The Supreme Court reversed, holding (1) the trial court failed to strictly comply with rule 11(e) because the record did not contain statements that clearly and unequivocally informed Lovell of his right to be presumed innocent or his right to a public trial by an impartial jury, and (2) under the "good cause" standard, the trial court's error to strictly comply with rule 11(e) was an error that required reversal. Remanded.

A highway patrol trooper noticed a car driven by Vance Morris did not have a visible license plate. Once he pulled Morris over, the trooper realized the car had a valid temporary registration tag displayed in its rear window. The trooper approached and spoke to Morris, ultimately gathering evidence leading to Morris's conviction for, inter alia, possession of a controlled substance and driving under the influence of alcohol or drugs. The court of appeals reversed, concluding that once the trooper realized his mistake, he lost the reasonable suspicion that justified the traffic stop, and any contact or further detention of Morris was unreasonable. The Supreme Court reversed, holding (1) when an officer acting in good faith is reasonably mistaken about the grounds for a traffic stop, he may initiate contact with the driver to explain his mistake but may not detain the driver any further, and, if during this encounter, new reasonable suspicion of criminal activity arises, the officer may act accordingly; and (2) because the trooper's stop was based on an objectively reasonable mistake of fact, he was allowed to approach Morris, and the odor of alcohol detected during this encounter allowed the trooper to constitutionally detain Morris further.