Justia Civil Rights Opinion Summaries

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.

Chance Robinson was charged with unlawful possession or use of a controlled substance based on the presence of methamphetamine in his bloodstream. The charge was grounded on provisions of the Utah Controlled Substances Act that make it unlawful for any person to "knowingly and intentionally" have "any measurable amount of a controlled substance in [his or her] body." Robinson pleaded guilty to the charges. On appeal Robinson argued that Utah's measurable amount provision violates the Utah and United States Constitutions. The Supreme Court affirmed the decision of the district court, holding (1) the provision does not violate the due process or the uniform operation of laws clause of the Utah Constitution; (2) the provision does not violate the constitutional principles set forth in Robinson v. California because it punishes the act of using or being under the influence of a controlled substance while in utah and requires the State to prove that such use was knowing and intentional; and (3) the provision does not violate the Due Process Clause of the Fourteenth Amendment.