Justia Constitutional Law Opinion Summaries

Articles Posted in Utah Supreme Court
by
The Supreme Court vacated the decision of the district court concluding that the adjudication of Plaintiff's intentional infliction of emotional distress claim against a church must be dismissed on the grounds that the adjudication of this claim would violate the Establishment Clause of the First Amendment, holding that recent changes in the Supreme Court's Establishment Clause jurisprudence required further development of the facts and legal arguments presented in this case.Plaintiff and her family attended the Roy Congregation of the Jehovah's Witnesses Church. When Plaintiff was sexually assaulted by another Jehovah's Witnesses congregant the Church investigated Plaintiff to determine whether she had engaged in the sin of "porneia." During the investigation, four Elders in the Church convened a disciplinary hearing in which they played an audio recording of the other congregant raping Plaintiff. Plaintiff then filed her complaint against the Church for intentional or negligent infliction of emotional distress. The district court dismissed the complaint, concluding that the Establishment Clause barred the claim. The Supreme Court vacated the district court's decision, holding that because the district court relied on a test that has recently been displaced by the Supreme Court, the case must be remanded for additional proceedings. View "Williams v. Kingdom Hall of Jehovah's Witnesses" on Justia Law

by
The Supreme Court affirmed the judgment of the court of appeals affirming the denial of post conviction relief sought by Defendant, holding that Defendant's claims failed.Defendant was convicted of sexually molesting his daughter. The convictions were affirmed on appeal. Defendant then filed a petition for post-conviction relief, asserting ineffective assistance of counsel. The reviewing court concluded that the Post-Conviction Remedies Act (PCRA), Utah Code 78B-9-101-110, barred Defendant's claims of ineffective assistance of trial counsel but allowed Defendant's ineffective assistance of appellate counsel claims to proceed. The court then denied relief. On appeal, the court of appeals held (1) the PCRA barred Defendant's "direct" claims, and (2) appellate counsel was de facto not ineffective. The Supreme Court affirmed, holding (1) the PRCA barred Defendant's direct claims against his trial counsel; and (2) Defendant's ineffective assistance of appellate counsel claims were without merit. View "McCloud v. State" on Justia Law

by
The Supreme Court affirmed the judgment of the district court denying Defendant's motion to reinstate his right to appeal, holding that this Court lacked appellate jurisdiction.Defendant was convicted and sentenced for child sodomy and child sex abuse. Several appellate proceedings later, Defendant filed this motion seeking to reinstate his appeal. The district court denied the motion and denied Defendant's invitation to strike down Utah's Plea Withdrawal Statute, Utah Code 77-13-6, as unconstitutional. The Supreme Court affirmed, holding that criminal defendants cannot raise untimely or unpreserved challenges through a Manning-like motion. View "State v. Brown" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of felony driving under the influence (DUI) and possession of drugs and drug paraphernalia, holding that the exclusionary rule does not apply where law enforcement relied reasonably on then-existing precedent.In affirming Defendant's conviction, the court of appeals held that the police had the reasonable suspicion necessary to temporarily detain Defendant in his vehicle and ask him to step out of it. The Supreme Court affirmed, holding (1) this Court repudiates the sweeping language of its opinion in State v. James, 13 P.3d 576 (Utah 2019), and holds that the identity of the opener of a car door may affect the reasonableness of any given police encounter; but (2) the evidence here was not subject to exclusion because the police acted objectively reasonably in reliance on the Supreme Court's opinion in James. View "State v. Malloy" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of aggravated robbery, holding that the trial court did not plainly err in its handling of the State's reports of a sleeping juror and that defense counsel did not provide ineffective assistance.On appeal, Defendant asserted that he was denied his Sixth Amendment right to a jury trial because at least one juror allegedly slept during the proceedings. The court of appeals concluded that Defendant failed to demonstrate that the trial court plainly erred in declining to inquire into the attentiveness of the juror and that Defendant failed to demonstrate that his trial counsel provided ineffective assistance in responding to observations that the juror may have been sleeping. The Supreme Court affirmed, holding (1) a trial court should respond to a report of an inattentive or drowsy juror in a manner that is proportional to the report before it, but the trial court in this case did not plainly err in its response; and (2) Defendant failed to show that his counsel's actions were deficient. View "State v. Marquina" on Justia Law

by
The Supreme Court reversed the judgment of the district court denying a civil stalking injunction sought by Kristi Ragsdale against George Fishler, holding that the district court erred.Ragsdale ran Eva Carlton Academy (ECA), a residential treatment program for young women, out of her home in a suburb. Fishler, Ragsdale's neighbor, expressed his objection to ECA's presence in the neighborhood by flipping off and swearing at Ragsdale and others entering or exiting ECA and by placing provocative signs in his yard. The district court denied Ragsdale's request for an injunction. The Supreme Court reversed on each issue raised by Ragsdale and vacated the district court's ruling on Fishler's fee request, holding that the district court erred by (1) concluding that Fishler's conduct was directed only at ECA; (2) failing to determine whether Fishler's conduct would cause a reasonable person in Ragsdale's circumstances to suffer fear or emotional distress; and (3) denying Ragsdale's injunction on the ground that the First Amendment protects Fishler's conduct. Because the Court's reversal of these issues may affect the basis for the district court's denial of Fishler's attorney-fees request, the Court vacated that decision and remanded for a new determination. View "Ragsdale v. Fishler" on Justia Law

by
The Supreme Court affirmed the decision of the Labor Commission awarding Appellant permanent partial disability under the Workers' Compensation Act (WCA), Utah Code 34A-2-101 to -1005, holding that the Commission's process for determining permanent partial disability benefits is constitutional and that the administrative law judge (ALJ) was not permitted to increase the amount of the award based on Appellant's subjective pain.Based on Commission guidelines, the ALJ based the amount of Appellant's award on a report provided by an assigned medical panel. Appellant argued on appeal that the process for determining permanent partial disability benefits was unconstitutional and that the ALJ erred in failing to augment the medical panel's impairment rating by three percent, resulting in an increased compensation award. The Supreme Court disagreed, holding (1) the adjudicative authority of ALJs has not been unconstitutionally delegated to medical panels; and (2) the Commission expressly precludes ALJs from augmenting an impairment rating based on a claimant's subjective pain. View "Ramos v. Cobblestone Centre" on Justia Law

by
The Supreme Court held that the strict compliance requirement of section 110 of Utah's Adoption Act, which permits a district court to terminate parental rights if the parent does not "fully and strictly comply" with the statutory requirements, as applied to Mother, is not narrowly tailored to achieve the State's compelling interest in prompt adoption proceedings.Mother gave birth to Child in 2010. Sometime thereafter, Child went to live with Adoptive Parents. In 2015, Adoptive Parents filed an adoption petition and served notice of the proceeding on Mother. The notice informed Mother that she had thirty days to file a motion to intervene or she would forfeit her parental rights in Child and would be barred from participating in the adoption proceeding. Mother attempted to intervene, but the district court struck her filing due to a procedural deficiency in the document and barred her from participating in the adoption proceeding. Mother filed a Utah R. Civ. P. 60(b) motion seeking relief from the order to strike, which district court denied. The Supreme Court reversed, holding that Mother's substantive due process rights were violated because section 110's strict compliance requirement is not narrowly tailored. View "In re K.T.B." on Justia Law

by
The Supreme Court affirmed Defendant's sentence of life in prison without the possibility of parole for aggravated murder, holding that Defendant was not entitled to a new penalty-phase trial.Specifically, the Supreme Court held (1) even if Defendant's trial counsel rendered ineffective assistance, Defendant was not prejudiced by that deficiency; (2) any error in admitting certain hearsay statements during trial was harmless beyond a reasonable doubt; (3) Defendant was not prejudiced by victim-impact evidence; (4) the trial court did not abuse its discretion by refusing to give a beyond-a-reasonable-doubt jury instruction under State v. Lafferty, 749 P.2d 1239 (Utah 1988); and (5) Defendant inadequately briefed his argument under the doctrine of cumulative error. View "State v. Drommond" on Justia Law

by
The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for being an accomplice to the crime of aggravated murder, holding that it was reasonably probable that the jury would not have convicted Defendant of aggravated murder absent jury instruction errors.After Defendant was convicted she appealed, arguing that her trial counsel was ineffective for failing to object to three errors in the jury instruction regarding accomplice liability. The court of appeals concluded that there were three errors in the jury instruction and that the performance of Defendant's trial counsel was deficient because he did not object to the errors. However, the court of appeals determined that the errors were not prejudicial because there was not a reasonable probability of a more favorable outcome absent the errors. The Supreme Court reversed and remanded the case for a new trial, holding (1) the jury instruction discussing the elements for accomplice liability on aggravated murder contained three errors; and (2) there was a reasonable probability that at least one juror would not have voted to convict Defendant in the absence of the errors. View "State v. Grunwald" on Justia Law