Justia Civil Rights Opinion Summaries

Petitioner was convicted of aggravated murder and sentenced to death. The Supreme Court affirmed the conviction and sentence. Petitioner subsequently filed a petition for postconviction relief, alleging that his counsel provided ineffective assistance at trial. The postconviction court granted summary judgment in favor of the State. Petitioner filed a notice of appeal in his postconviction proceedings and then filed a Utah R. Civ. P. 60(b) motion to set aside the postconviction court’s final judgment. The postconviction court denied the motion. The Supreme Court consolidated the appeals and affirmed the postconviction court’s grant of summary judgment and denial of Rule 60(b) relief, holding (1) Petitioner failed to raise a genuine issue of material fact for each of his ineffective assistance of counsel claims; and (2) the postconviction court did not abuse its discretion when it denied Petitioner’s motion for relief from judgment pursuant to Rule 60(b). View "Honie v. State" on Justia Law

Defendant pled guilty to unlawful sexual conduct with a minor. Defendant later moved to withdraw his guilty plea based upon ineffective assistance of counsel and a violation of Utah R. Crim. P. 11, arguing that his plea was not knowing or voluntary because neither his defense counsel nor the trial court informed him that his guilty plea carried with it the requirement that Defendant register on the state’s sex offender registry. The district court denied Defendant’s motion to withdraw, concluding that neither defense counsel nor the district court had an obligation to inform him of the registration requirement because the registration requirement was a collateral consequence of the guilty plea. The Supreme Court affirmed, holding that the requirement to register as a sex offender is properly classified as a collateral consequence of a defendant’s guilty plea, and therefore, neither defense counsel nor the trial court in this case was constitutionally obligated to inform Defendant of the registration requirement before his guilty plea was accepted as knowing and voluntary. View "State v. Trotter" on Justia Law

After a jury trial, Appellant was convicted of murder and child abuse for the death of her two-year-old son, Alex. Appellant appealed her convictions on several grounds. The Supreme Court affirmed, holding (1) a preponderance of the evidence is required to admit evidence of prior bad acts, and the trial court did not abuse its discretion in admitting evidence of prior child abuse under Utah R. Evid. 404(b); (2) Appellant’s defense counsel was not ineffective for, among other things, deciding not to introduce expert testimony regarding Battered Woman’s Syndrome because the trial strategy he selected was objectively reasonable; and (3) there was no cumulative error. View "State v. Lucero" on Justia Law

After a jury trial, Defendant was convicted of aggravated murder, desecration of a body, kidnapping, and aggravated kidnapping. Defendant was sentenced to life without parole for his murder conviction. Defendant appealed, arguing, among other things, that it was error for his case to be tried in Cache County with Box Elder County jurors. The Supreme Court affirmed Defendant’s conviction of and sentence for aggravated murder and desecration of a body but reversed and vacated his kidnapping and aggravated kidnapping convictions, holding (1) the trial judge did not abuse his discretion in deciding to hold the trial in Cache County with a jury consisting of residents of neighboring Box Elder County; and (2) because Defendant’s kidnapping and aggravating kidnapping convictions merged, the kidnapping conviction should have been vacated, and Defendant’s aggravated kidnapping conviction should have merged with his aggravated murder conviction. View "State v. Nielsen" on Justia Law

Defendant pled guilty to criminally negligent automobile homicide and driving under the influence of alcohol, reserving his right to challenge the denial of his motion to suppress evidence obtained through a blood draw. Defendant’s blood was drawn after the police were issued eWarrants through the Utah Criminal Justice Information System. On appeal, Defendant argued that because the affidavits submitted by the police in order to obtain the warrants were not supported by an oath or affirmation, as required by both the Utah and United State constitutions, the warrants were unconstitutional. The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress, holding that the affidavits comported with the historical understanding of what constitutes a constitutionally valid “affirmation,” and therefore, the affidavits were constitutionally sufficient to support the issuance of the warrants in this case. View "State v. Gutierrez-Perez" on Justia Law

The State charged Defendant with various crimes, including aggravated burglary and aggravated assault. After the jury was empaneled and sworn and on the second day of trial, the trial judge announced that she was recusing herself and declaring a mistrial. The case was subsequently reassigned for retrial under a new judge. Defendant moved to dismiss the charges against him on the grounds of double jeopardy. The trial court denied the motion, concluding that the mistrial did not act as an acquittal because the mistrial was legally necessary. The Supreme Court reversed, holding (1) the burden to create a record for and sufficiently justify the mistrial fell on the trial court and the State, and, in this case, the legal necessity for a mistrial was not established on the record; and (2) Utah’s constitutional protections against double jeopardy precluded a second trial under such circumstances. View "State v. Manatau" on Justia Law

Christopher Carlton, a Pennsylvania resident, was in a relationship with Shalanda Brown, who was pregnant with Carlton’s child. Unbeknownst to Carlton, Brown traveled to Utah, where she gave birth to a baby girl and relinquished her parental rights to Adoption Center of Choice, Inc. Because no putative father was registered with respect to the child, Adoption Center commenced and adoption proceedings for the child, which were later finalized. Brown, however, had informed Carlton that the child had died. After Brown subsequently told Carlton that the baby was still alive and had been given up for adoption, Carlton filed an amended petition to establish paternity challenging the constitutionality of the Utah Adoption Act and the extent of the rights it affords to putative fathers who wish to contest adoptions in Utah. The district court dismissed Carlton’s petition based on a lack of standing. The Supreme Court reversed in part, holding that the district court erred in (1) denying Carlton leave to amend his petition to cure standing defects to assert the constitutional claims, and thereby, in dismissing Carlton's constitutional claims; and (2) dismissing Carlton’s claim for intentional infliction of emotional distress. Remanded. View "Carlton v. Brown" on Justia Law

After a jury trial, Defendant was convicted of misdemeanor sexual battery. The court of appeals reversed the conviction and remanded for a new trial, concluding that the district court plainly erred and Defendant's trial counsel was ineffective in allowing the investigative detective's testimony on redirect examination about other allegations of sexual misconduct against him. The Supreme Court reversed, holding that trial counsel was not ineffective in referencing and admitting the Utah R. Evid. 404(b) evidence, and the district court did not commit plain error in allowing the evidence to be presented. In so holding, the Court did not address the State's argument that a gap in the record of a criminal trial should always be interpreted in favor of the State. View "State v. Bedell" on Justia Law

After a jury trial, Appellant was convicted of two counts of aggravated sexual assault and one count of robbery for the 1996 attack and sexual assault of a twenty-three-year-old woman. On appeal, Appellant contended that the statute of limitations had run before the State commenced its prosecution of Appellant and, alternatively, that his right to a speedy trial was violated. The Supreme Court affirmed Appellant's convictions, holding that the State commenced Appellant's prosecution within the applicable statute of limitations and that Appellant's right to a speedy trial was not violated, where, while this case involved an extraordinary delay, the delay was not the fault of the State and Appellant was not prejudiced. View "State v. Young" on Justia Law

After a jury trial, Appellant was convicted of two counts of aggravated sexual abuse of a child and one count of dealing in material harmful to a minor. Defendant appealed, arguing, among other things, that the prosecutor prejudiced the jury by making several improper comments during closing arguments. The Supreme Court vacated Defendant's convictions and remanded for a new trial on all counts, holding (1) Defendant failed to preserve his arguments based on prosecutorial misconduct for appeal; but (2) nevertheless, defense counsel's failure to object to the prosecutor's conduct at trial constituted ineffective assistance of counsel. View "State v. Larrabee" on Justia Law