Justia Civil Rights Opinion Summaries

In this case brought by an alleged victim of child-sex abuse years after the alleged abuse occurred, the Supreme Court held that the Utah Legislature is constitutionally prohibited from retroactively reviving a time-barred claim in a manner depriving a defendant of a vested statute of limitations defense.Plaintiff, who alleged that Defendant sexually abused her in 1981, conceded that each of her claims had expired under the original statute of limitations. Plaintiff, however, argued that (1) her claims were revived when the legislature, in 2016, enacted Utah Code 78B-2-308(7), and (2) her claims against Defendant were timely filed under this statue. The federal court certified this case to the Supreme Court asking the Court to clarify whether the legislature had the authority to expressly revive time-barred claims through a statute. The Supreme Court held (1) the legislature lacks the power to retroactively vitiate a ripened statute of limitations defense under the Utah Constitution; and (2) therefore, section 78B-2-308(7) is an unconstitutional exercise of legislative power. View "Mitchell v. Roberts" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of aggravated sexual assault and aggravated assault, holding that Defendant was not prejudiced by any alleged error in the jury instruction for rape and that the State had no duty under Brady v. Maryland, 373 U.S. 83 (1963), to conduct a forensic examination of the complainant's cell phone before trial.The court of appeals affirmed Defendant's convictions, holding that (1) the district court had not erroneously instructed the jury on the elements of rape, and (2) the State did not commit a Brady violation. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by his counsel's failure to object to the jury instruction on the elements of rape, and, going forward, this Court endorses the use of Model Utah Jury Instruction 1605 for rape; and (2) the State did not violate Brady when it did not complete a forensic examination of the complainant's cell phone. View "State v. Newton" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of attempted murder, holding that the court of appeals did not err in denying Defendant's Utah R. App. P. 23B motion, nor was Defendant prejudiced by his trial counsel's decision not to call an expert who would have testified about the problems inherent in eyewitness identifications.On appeal, Defendant argued that his trial counsel rendered ineffective assistance by failing to call the eyewitness testimony expert, who his prior counsel had previously identified and disclosed. Defendant also filed a Rule 23B motion asking the court to remand so that he could supplement the record with facts concerning the uncalled expert. The court of appeals denied the Rule 23B motion and affirmed Defendant's conviction. The Supreme Court affirmed, holding that the court of appeals (1) did not err by concluding that Defendant failed to present a sufficient basis for remand under Rule 23B; and (2) did not apply an incorrect version of the Washington v. Strickland, 466 U.S. 668 (1984), standard to its conclusion. View "State v. Gallegos" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that Defendant's trial counsel provided ineffective assistance during Defendant's criminal trial, holding that defense counsel's performance was not deficient.Defendant was convicted of forcible sexual abuse of a fifteen-year-old. The court of appeals reversed the conviction, concluding that because counsel did not object to the jury instruction for forcible sexual abuse Defendant received ineffective assistance of counsel. The Supreme Court reversed, holding that the court of appeals erred in concluding that counsel's acquiescence to the jury instruction could not have been sound strategy and that Defendant failed to overcome the strong presumption that his counsel exercised reasonable professional judgment. View "State v. Ray" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's conviction for the murder of his wife on grounds that Defendant received ineffective assistance of counsel, holding that there was insufficient information to conclude that counsel's course of conduct was deficient or prejudicial.During trial, when Defendant tried to testify about a threat he claimed his wife had made a few days before he shot her, the trial court excluded the testimony on hearsay ground. On appeal, Defendant argued that his lawyer's failure to argue that the threat was not hearsay constituted ineffective assistance. The court of appeals agreed and reversed Defendant's conviction. The Supreme Court reversed, holding that because the court of appeals did not know or consider the specifics of the threat, it was impossible to determine whether Defendant's trial counsel was ineffective under Strickland v. Washington, 466 U.S. 668 (1984). View "State v. Scott" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming Defendant's conviction of failure to signal for two seconds and failure to obey traffic control devices, holding that the Utah Constitution does not guarantee Defendant a jury trial for his traffic violations.At the time Defendant was charged, the Utah Code classified the offenses as class C misdemeanors. At the arraignment hearing the City amended both charges to infractions, thereby depriving Defendant of a jury trial. Defendant moved to dismiss the information charging him with infractions, arguing that the Utah Constitution guarantees a right to a jury trial in all criminal prosecutions, including those for infractions. The justice court denied Defendant's motion to dismiss and request for a jury trial and convicted Defendant. On appeal, the district court denied Defendant's motion for a jury trial and convicted him of both charges. The Supreme Court affirmed, holding that minor offenses do not trigger the right to a jury trial under article I section 12 of the Utah Constitution. View "South Salt Lake City v. Maese" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions for aggravated kidnapping, aggravated robbery, and obstruction of justice, holding that the court of appeals properly concluded that Defendant's free will was not overborne in confessing and making other incriminating statements to the police and properly concluded that a jury instruction given at trial was faulty but did not result in prejudice to Defendant.On appeal, Defendant argued that the court of appeals erred in (1) affirming the trial court's determination that his statements were admissible at trial as impeachment evidence, despite a violation of his Miranda rights, which barred the statements from being used in the Sate's case-in-chief; and (2) erred in affirming his conviction for aggravated robbery despite a jury instruction that incorrectly recited the requisite mental state for the offense. The Supreme Court affirmed, holding (1) the court of appeals correctly affirmed that Defendant's statements to police were voluntary and that his confession and incriminating statements could be used for impeachment purposes in the event that Defendant chose to testify; and (2) the faulty jury instruction did not affect the outcome or the verdict. View "State v. Apodaca" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing Plaintiff's claims against the Iron County attorney, holding that Plaintiff failed to demonstrate that a previous federal court order dismissing Plaintiff's official-capacity claims against the same defendant with prejudice lacked preclusive effect.Plaintiff filed suit in federal district court asserting claims against several defendants, including the Iron County attorney in his official capacity. The federal court dismissed the claims with prejudice. Plaintiff refiled her suit in state court, alleging state constitutional violations against several defendants, including the Iron County attorney. The district court dismissed the case with prejudice, concluding that Plaintiff's claims were barred by res judicata. The court of appeals affirmed. The Supreme Court affirmed, holding that Plaintiff failed to rebut the presumption that the federal court order was "on the merits" for purposes of the claim preclusion doctrine. View "Cheek v. Iron County Attorney" on Justia Law

The Supreme Court affirmed the post-conviction district court's conclusion that appellate counsel's performance did not prejudice Appellant, holding that Appellant was not prejudiced by his appellate counsel's failure to investigate the alleged ineffective assistance of Appellant's trial counsel.Appellant was conviction of aggravated murder and attempted aggravated murder. After a direct appeal, Appellant filed a petition seeking relief under the Post-Conviction Remedies Act, alleging that his trial counsel and appellate counsel were both constitutionally deficient. After a remand, the district court concluded that appellate counsel's performance was deficient because she had failed to investigate certain arguments while preparing the appeal but that Appellant was not prejudiced because his trial counsel had not rendered ineffective assistance. The Supreme Court affirmed, holding (1) this Court may consider the evidence entered into the record during the proceedings below; and (2) the district court correctly concluded that Appellant did not suffer prejudice as a result of his appellate counsel's deficient performance. View "Ross v. State" on Justia Law

The Supreme Court reversed the judgment of the district court denying the petition filed by Petitioners, a same-sex married couple and a woman and her husband requesting that the court validate their agreement that the woman act as a gestational surrogate for the couple, holding that Utah Code 78B-15-802(2)(b), which precludes same-sex male couples from obtaining a valid gestational agreement, is unconstitutional.A married couple, both men, entered into an agreement with a woman and her husband to have the woman act as a gestational surrogate to carry a fertilized embryo that contained the genetic material of one of the couple. This type of gestational agreement is not enforceable in Utah unless it is validated by a tribunal, and a court may not validated the agreement if medical evidence is not presented showing that the "intended mother" is unable to bear a child or will suffer health consequences if she does. Petitioners filed a petition requesting that the district court validate their gestational agreement, but the court denied the petition because neither of the intended parents were women. The Supreme Court reversed, holding that the statute is unconstitutional and that the unconstitutional subsection should be severed. The Court then remanded this case for further proceedings. View "In re Gestational Agreement" on Justia Law