Justia Constitutional Law Opinion Summaries

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

Federal National Mortgage Association (FNMA) initiated an unlawful detainer action against Appellant, claiming ownership of Appellant's home pursuant to a trustee's deed it obtained from ReconTrust, a national bank that conducted a nonjudicial foreclosure sale in its capacity as trustee of the trust deed that Appellant had executed to secure her mortgage. After an immediate occupancy hearing, the district court entered an order of restitution requiring that Appellant vacate her home. At issue on appeal was whether ReconTrust had authority to conduct the foreclosure sale and convey Appellant's home to the FNMA where Utah Code 57-1-21 and 57-1-23 limits the power of sale to trustees who are either members of the Utah State Bar or title insurance companies with an office in Utah. The district court concluded that ReconTrust, as a national bank, was authorized to conduct the sale under federal law and that federal law preempted Utah law. The Supreme Court vacated the district court's order of restitution, holding that the relevant Utah statutes were not preempted by federal law, and therefore, a national bank seeking to foreclose real property in Utah must comply with Utah law. Remanded. View "Fed. Nat'l Mortgage Ass'n v. Sundquist" on Justia Law

Plaintiffs were camping with their young son, Sam, when a bear pulled Sam from out of his tent and killed him. The bear was the same bear that had attacked another camper in the same campsite earlier that day. Plaintiffs sued the State, alleging that the State negligently failed to warn them of the dangerous condition created by the bear. The district court initially dismissed Plaintiffs' claims under the permit exception to the Utah Governmental Immunity Act. The Supreme Court reversed. On remand, the State filed a motion for summary judgment, raising two alternative arguments that the Supreme Court declined to address in Francis I. The district court subsequently granted summary judgment for the State on both duty and immunity grounds. The Supreme Court reversed, holding (1) the State was entitled to present its alternative arguments on remand; (2) the State owed Plaintiffs a duty because it undertook no specific action to protect them as the next group to use the campsite; and (3) the natural condition exception to the Immunity Act did not immunize the State from liability because a bear is not a "natural condition on publicly owned or controlled lands." View "Francis v. State" on Justia Law

After a jury trial, Defendant was convicted of murder. Fourteen years later, Defendant filed a petition for a post-conviction determination of factual innocence pursuant to Utah's Post-Conviction Remedies Act (PCRA). After an evidentiary hearing, the post-conviction court vacated Defendant's murder conviction, determining (1) the PCRA allows a determination of factual innocence to be based on a combination of newly discovered evidence and previously available evidence; and (2) Defendant established her factual innocence by clear and convincing evidence. The Supreme Court affirmed, holding (1) a post-conviction determination of factual innocence can be based on both newly discovered evidence and previously available evidence; and (2) the State did not properly challenge the post-conviction court's factual findings, and therefore, the post-conviction court's ultimate determination that Defendant was factually innocent was affirmed. View "Brown v. State" on Justia Law

Defendant confessed to helping Glenn Griffin commit murder. The State charged both Griffin and Defendant with the crime. The State prosecuted Griffin first and, concerned that Defendant would invoke his privilege against self incrimination and refuse to testify, offered Defendant use immunity. The district judge subsequently issued an order compelling Defendant to testify, but Defendant refused. Thereafter, the State charged Defendant with three counts of obstruction of justice. After a hearing, the magistrate judge refused to bind Defendant over for trial and dismissed the obstruction of justice charges. The court of appeals affirmed, finding that State had failed to present sufficient evidence of intent to obstruct. The Supreme Court reversed, holding that the evidence was sufficient to bind Defendant over for trial for obstruction of justice. Remanded. View "State v. Maughan" on Justia Law

After a jury trial, Defendant, who was temporarily staying in the spare bedroom of the victim's father's house, was convicted of aggravated sexual abuse of a child. Defendant's conviction was based on the holding that he occupied a "position of special trust" in relation to the victim under Utah Code 76-5-404.1(4)(h). The district court and court of appeals both held Defendant was an "adult cohabitant" of a parent of the child, which was one of several positions specifically referenced in section 76-5-404.1(4)(h). The Supreme Court vacated Defendant's conviction and remanded, holding (1) the fact that a defendant occupies one of the positions listed in section 76-5-404.1(4)(h) is insufficient, standing alone, to establish the crime of aggravated sexual abuse of a child; (2) for the State to establish aggravated sexual abuse of a child under subsection 4(h), it must prove both that the defendant occupied a "position of authority" over the victim and that the position gave the defendant the ability to "exercise undue influence" over the victim; and (3) because the lower courts did not require the State to establish both elements, Defendant's conviction must be vacated. View "State v. Watkins" on Justia Law