Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of two counts of aggravated murder and two counts of attempted murder. Defendant was sentenced to life without parole for each aggravated murder conviction and three years to life for each attempted murder conviction. The Supreme Court affirmed, holding (1) although the district court erred when it limited and excluded the testimony of the defense's expert witnesses, these errors were harmless; (2) the combined result of these errors did not undermine the Court's confidence in the verdict; and (3) Utah Code 76-3-207.7, which provides the sentencing scheme for first degree felony aggravated murder, is constitutional on its face and was constitutionally applied to Defendant. View "State v. Perea" on Justia Law

In April 2002, Ogden City Police Officer Troy Burnett and another officer searched Plaintiff's motel room and found drugs and a firearm. Plaintiff pled guilty to two federal offenses, but the court of appeals overturned Plaintiff's conviction, concluding that the search violated the Fourth Amendment. Plaintiff subsequently brought a claim under 42 U.S.C. 1983 against Burnett in federal court based on the unreasonable search. Under the Tenth Circuit Court of Appeals' decisions at the time Plaintiff filed his complaint, approximately two years remained in the limitations period before his claim would become time-barred. A U.S. Supreme Court decision four days after the filing, however, overturned the Tenth Circuit's decisions and rendered Plaintiff's complaint approximately ten months late. The district court granted summary judgment to Burnett, concluding that, as a result of the U.S. Supreme Court's decision, Plaintiff's claim was time-barred and Plaintiff was not entitled to equitable tolling. The Tenth Circuit Court of Appeals subsequently certified a question to the Utah Supreme Court, which answered by holding that under Utah law, an intervening change in controlling law that extinguishes a previously timely cause of action does merit equitable tolling of the statute of limitations. View "Garza v. Burnett" on Justia Law

In 1993, Jed Gressman was convicted of aggravated sexual assault and sentenced to a term of five years to life. In 1996, Gressman moved to dismiss the charges against him based on newly-discovered evidence. The district court vacated Gressman's conviction based on the newly-discovered evidence. In 2009, Gressman filed suit under the Post-Conviction Remedies Act (PCRA) seeking to obtain his factual innocence and obtain financial assistance. Gressman died during pendency of the suit, so counsel moved to substitute Gressman's widow. The district court substituted Gressman's widow, granted Gressman's widow's motion for summary judgment, and awarded Gressman's widow PCRA assistance payments, including prejudgment interest. The State appealed. The Supreme Court reversed for further proceedings, holding (1) Gressman's PCRA claims survived his death, and thus, the district court properly substituted Gressman's widow as the plaintiff in this suit; (2) the district court erred when it found that the vacatur of Gressman's conviction conclusively established his factual innocence as defined by the PCRA; and (3) the district court erred in awarding prejudgment interest. View "Gressman v. State" on Justia Law

Defendant pled guilty to possession of a controlled substance in a drug free zone and was sentenced to a term of incarceration for five years to life. Defendant appealed, arguing that the district court erred in denying his motion to suppress evidence obtained through a search of his vehicle. Specifically, Defendant argued that the search was unlawful because, among other reasons, the officers did not have reasonable suspicion that there were drugs in his vehicle when they stopped him for a traffic infraction. The Supreme Court reversed, holding that the district court erred when it denied Defendant's motion to suppress the evidence, as the officers, who had possessed reasonable suspicion that Defendant was engaged in or about to be engaged in criminal activity, improperly extended the original purpose of the stop, which was to investigate a minor traffic infraction, and instead undertook a prolonged investigation into Defendant's possible drug activity. Remanded. View "State v. Gurule" on Justia Law

Defendant confessed to shooting a female victim during a custodial interrogation by detectives. Defendant moved to suppress the confession on the grounds that it was coerced. The district court granted the motion based on the detectives' invocation of Defendant's children as a method to get a confession. After clarifying that a confession is involuntary if the will of the accused has been overcome, the Supreme Court reversed, holding that, under the totality of the circumstances of this case, Defendant's free will was not overcome, and therefore, the district court erred in concluding that the references in the interrogations to Defendant's children were coercive police tactics that rendered Defendant's confession involuntary. Remanded. View "State v. Arriaga-Luna" on Justia Law

Defendant pled guilty to aggravated murder and aggravated assault. Defendant subsequently filed a motion to withdraw his plea, stating that he was confused when he entered his plea. The district court denied the motion, concluding that Defendant was adequately informed of the nature of the charge and was not confused. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) Defendant received constitutionally adequate notice of the nature of the charge of his limited appeal rights; and (2) the district court did not abuse its discretion in determining that Defendant entered his plea knowingly and voluntarily. View "State v. Candland" on Justia Law

Officer Dennis Nelson, a police officer with the Orem City Police Department (OCPD), was terminated from his position for using excessive force during a booking at the Orem City Jail. The Orem City Employee Appeals Board (Board) upheld the termination. The court of appeals upheld the Board's decision, concluding (1) the OCPD's decision to terminate Nelson was not inconsistent with prior instances of discipline under OCPD's excessive force policy; (2) alternatively, the Board justified any disparate application of OCPD's policy; and (3) the Board did not violate Nelson's procedural due process rights at his hearing before the Board. The Supreme Court affirmed, holding (1) the court of appeals did not err in applying an abuse of discretion standard of review; and (2) the court of appeals correctly found that any procedural due process violations at the hearing were harmless. View "Nelson v. City of Orem" on Justia Law

The City police department fired a police officer (Plaintiff) for reporting for duty while under the influence of alcohol. The board of appeals and court of appeals affirmed the decision. The Supreme Court affirmed, holding (1) substantial evidence supported the conclusion that Plaintiff was under the influence of alcohol, in violation of the City's alcohol policy, as the portable breath test administered to Plaintiff accurately measured Plaintiff's breath alcohol and blood alcohol content; and (2) Utah Code 34-38-7 does not prohibit the City from deviating from its specified procedure of testing urine to establish blood alcohol content, as the statute does not apply to the City. View "Becker v. Sunset City" on Justia Law

After a trial, Defendant was convicted of vaginal rape and forcible anal sodomy. Defendant appealed, arguing that the trial court's exclusion prior instances of sexual conduct between Defendant and the victim under Utah R. Evid. 412(b)(2)(A) was error. Specifically, Defendant unsuccessfully sought to offer evidence that he and the victim had previously engaged in consensual oral and anal sex through his own testimony and the testimony of witnesses. The Supreme Court reversed, holding that the trial court's exclusion of Defendant's proffered sexual history evidence under Rule 412(b)(2)(A) was error that undermined the jury's verdict. Remanded for a new trial. View "State v. Richardson" on Justia Law

Defendant, a New Mexico resident, was arrested in Utah and indicted on federal charges of coercion and enticement of a fifteen-year-old. Defendant was returned to New Mexico to await trial and remained there for more than two years, returning to Utah on a few occasions to attend proceedings in federal court. The federal charges were subsequently dismissed. Thereafter, the State of Utah charged Defendant with enticement of a minor. Defendant moved to dismiss the charge as untimely under the applicable statute of limitations. The district court denied Defendant's motion. At issue on appeal was the applicability of the criminal tolling statute, which tolls the limitations period while a defendant is out of the state. The Supreme Court affirmed, holding that the criminal tolling statute applied to Defendant even though he was present in Utah during the course of the federal court proceedings, as (1) Defendant was only loosely subject to the authority of the State during the federal proceedings against him; and (2) applying the statute to Defendant did not violate the Uniform Operation of Laws provision of the Utah Constitution. View "State v. Canton" on Justia Law