Justia Constitutional Law Opinion Summaries

Articles Posted in Utah Supreme Court
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The Supreme Court reversed the decision of the court of appeals vacating Defendant's convictions on the grounds that his counsel had been ineffective, holding that errors on the part of trial counsel did not prejudice Defendant.Defendant was convicted of murder and several related charges. The court of appeals vacated the convictions, determining that trial counsel was ineffective in failing to object to the use of evidence about Defendant's silence while being arrested and in not objecting to the manslaughter jury instruction, prejudicing Defendant. The Supreme Court reversed, holding (1) defense counsel was ineffective for not objecting to the manslaughter jury instruction, which incorrectly shifted the burden of proof for imperfect self-defense, but the error was not prejudicial; and (2) assuming that defense counsel was ineffective for failing to object to commentary by the prosecution in Defendant's silence after arrest, the error was not prejudicial. View "State v. Bonds" on Justia Law

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The Supreme Court affirmed the judgment of the district court dismissing the challenges brought by Salt Lake City to four provisions of the Utah Inland Port Authority Act, holding that the challenged zoning provisions did not violate the Utah Constitution.The Act requires that Salt Lake City, West Valley City, and Magna adopt specific zoning regulations and permissions favorable to developing an inland port in the area. Salt Lake brought this action alleging that four provisions of the Act violated the Utah Constitution's Uniform Operation of Laws and Ripper clauses. The district court rejected the City's claims. The Supreme Court affirmed, holding (1) the zoning provisions were rationally related to a legitimate legislative purpose and therefore did not violate the Uniform Operation of Laws Clause; and (2) the zoning provisions did not delegate municipal functions in violation of the Ripper Clause. View "Salt Lake City Corp. v. Inland Port Authority" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals holding that the conduct of two court personnel while sharing a nonpublic courthouse elevator with a jury during trial triggered a rebuttable presumption of prejudice against Defendant, holding that the court of appeals did not err.The court personnel in this case - a uniformed highway patrolman and a court IT technician - told the jurors, in so many words, to find Defendant guilty and to "hang him." The trial court bailiff also stood in the elevator but did not intervene in the exchange. The court of appeals reversed Defendant's conviction and remanded the case for a new trial. The Supreme Court affirmed, holding that the impermissible contact violated Defendant's right to an impartial jury and triggered a rebuttable presumption that Defendant was prejudiced as a result. The Court remanded the case to the district court for a determination of whether the State met its burden to rebut this presumption. View "State v. Soto" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction and the denial of his motion to suppress, holding that the State did not meet its burden in rebutting a presumptively unreasonable seizure.The police found Defendant sleeping in his car in a McDonald's parking lot. The officers asked Defendant to exist his vehicle and ordered him to perform a field sobriety test. Defendant was subsequently charged with driving under the influence of alcohol. Defendant moved to suppress evidence and statements as a result of his seizure, arguing that his seizure and subsequent searches were unlawful. The district court denied the motion, concluding that Defendant's seizure was justified by the community caretaking doctrine. The Supreme Court reversed, holding that the State did not meet is burden to rebut the presumption of unreasonableness. View "State v. Smith" on Justia Law

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The Supreme Court held that the court of appeals correctly held that the conduct of two court personnel triggered a rebuttable presumption against Defendant, holding that remand was required.The court personnel in this case shared a nonpublic courthouse elevator with a jury during Defendant's trial and either told the jurors to find Defendant guilty and "hang him" or stood quietly in the elevator. On appeal, Defendant argued that the improper juror contact denied him his constitutional right to a fair trial and impartial jury. The court of appeals agreed and reversed Defendant's conviction and remanded the case for a new trial. The Supreme Court affirmed, holding (1) the improper contact violated Defendant's right to an impartial jury and triggered a rebuttable presumption that Defendant was prejudiced by the constitutional error; and (2) the case must be remanded for a determination as to whether the State had met its burden. View "State v. Soto" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirming the district court's dismissal of Defendant's motion to suppress, holding that there was no error.Testing of a buccal swab of Defendant's cheek showed that Defendant was a genetic match for DNA found on evidence at the scene of a murder. Prior to his criminal trial, Defendant moved to suppress the DNA evidence, arguing that the forcible collection of the sample had violated his Fourth Amendment rights. The district court denied the motion, and a jury convicted Defendant of murder, aggravated burglary, and possession of a weapon by a restricted person. The court of appeals affirmed. The Supreme Court affirmed, holding that the court of appeals did not err in affirming the district court's denial of Defendant's motion to suppress evidence obtained from the buccal swab, nor did it err in rejecting Defendant's statutory arguments. View "State v. Evans" on Justia Law

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The Supreme Court in this criminal case repudiated the sweeping language of its opinion in State v. James, 13 P.3d 576 (Utah 2000), and held that it can no longer be said that it makes no constitutional difference, as regards community caretaking concerns, whether a police officer opens a car door or asks a driver to do so.Defendant was charged with felony DUI and possession of drugs and drug paraphernalia. Defendant moved to suppress the evidence discovered after an officer looked inside his pickup truck, which was parked in a store parking lot, opened the truck door, and saw evidence of drug paraphernalia between Defendant's feet. The district court denied the motion. The court of appeals affirmed on alternative grounds, holding that the officer was justified in opening the car door incident to a lawful traffic stop under the standard in James. The Supreme Court affirmed, holding (1) the identity of the door-opener may well affect the reasonableness of a given police encounter; and (2) the denial of Defendant's motion to suppress was proper under the authority of Davis v. United States, 564 U.S. 229 (2011). View "State v. Malloy" on Justia Law

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The Supreme Court affirmed Defendant's conviction of dealing in material harmful to a minor, a third degree felony under Utah Code 76-10-1206, holding that Defendant's argument that the statute was unconstitutional as applied failed.As part of a sexually explicit online chat, Defendant sent photographs of women with nude breasts to someone who he thought was an underage girl. Defendant was convicted of dealing in material harmful to a minor, in violation of section 76-10-1206. On appeal, Defendant argued that because the photographs he sent did not depict sexual activity they could not qualify as obscenity, and therefore, the photographs were protected speech under the First Amendment. The Supreme Court affirmed, holding that where nudity may be obscene to minors without depicting sexual conduct, Defendant's argument that the statute was unconstitutional as applied to his conduct failed. View "State v. Watts" on Justia Law

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The Supreme Court affirmed Defendant's conviction of distribution of or arranging to distribute a controlled substance, holding that the trial court did not err in denying Defendant's challenge brought under Batson v. Kentucky, 476 U.S. 79 (1986) and that sufficient evidence supported the conviction.On appeal, Defendant argued that the State violated his right to equal protection when it used a peremptory strike to remove the only person of color from the jury pool. The trial court denied Defendant's Batson challenge, and the jury subsequently convicted him of drug-related counts. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's Batson challenge; and (2) there was sufficient evidence to support Defendant's conviction. View "State v. Aziakanou" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals ruling that the Post-Conviction Remedies Act (PCRA), Utah Code 78B-9-101-110, barred Appellant's claims because they "could have been" brought on appeal, holding that Appellant's claims failed because trial counsel was not ineffective.Appellant was convicted of sexually molesting his daughter. The convictions were affirmed on appeal. Appellant later filed a petition for post-conviction relief, arguing that his trial counsel was ineffective and that his appellate counsel was ineffective for failing to raise ineffectiveness claims on direct appeal. The reviewing court denied relief. The court of appeals affirmed, ruling that the PCRA barred Appellant's claims. The Supreme Court affirmed, holding (1) the PCRA barred Appellant's direct claims against his trial counsel; and (2) appellate counsel was not ineffective. View "McCloud v. State" on Justia Law