Justia Constitutional Law Opinion Summaries

Appellants were a group of current and former legislators, other elected and unelected government officials, and citizens. Appellants filed suit against the State's attorney general, treasurer, and the executive director of the Department of Human Resources (collectively, Appellees), seeking a declaration that Senate Bill 2, a bill related to education, was unconstitutional and an injunction against its implementation. Appellants claimed the Bill was unconstitutional in four respects. The first two claims fell under Utah Const. art. VI, 22, and the second two claims fell under Utah Const. art. X, 3. The district court dismissed the Article VI claims for failure to state a claim, and later granted Appellees' motion for summary judgment on the Article X claims. At issue on appeal was whether Appellants had standing to bring these claims in the first place. The Supreme Court held (1) Appellants had public-interest standing to bring the Article VI claims, but the district court properly dismissed the claims under Utah R. Civ. P. 12(b)(6); and (2) Appellants did not have standing to bring the Article X claims, and therefore, summary judgment on these claims, rather than dismissal, was improper. View "Gregory v. Shurtleff" on Justia Law

Defendant was working as an aide at a middle school when she was convicted of rape, forcible sodomy, and forcible sexual abuse for incidents involving a fifteen-year-old student student and his friend. The trial judge arrested the judgment and granted a new trial on all counts based on evidentiary errors and several irregularities that occurred during trial. The State appealed. The Supreme Court reversed the order granting a new trial and reinstated Defendant's convictions, holding (1) the evidentiary ruling excluding evidence of the victim's sexual predisposition was proper; and (2) the other claimed errors and irregularities did not require reversal because they did not prejudice Defendant. View "State v. Billingsley" on Justia Law

In 2006, the Central Utah Water Conservancy District (District) filed an action to condemn six waterfront lots owned by Petitioner. When negotiations reached an impasse on the value of the lots, the District instituted the underlying condemnation proceeding. The jury returned a verdict for Petitioner in the amount of $56,000. Petitioner filed a motion for a new trial, which the district court denied. Petitioner filed an appeal less than thirty days after the entry of the district court's ruling and order. The court of appeals dismissed Petitioner's appeal without prejudice based upon lack of jurisdiction, holding that under Utah R. Civ. P. 7(f)(2) and the Supreme Court's decision in Giusti v. Sterling Wentworth Corp., Petitioner's appeal was not ripe because it was not taken from a final, appealable order. The Supreme Court affirmed, holding that under Rule 7(f)(2), Petitioner's appeal was premature and that the court of appeals therefore correctly dismissed it without prejudice. View "Central Utah Water Conservancy Dist. v. King" on Justia Law

Appellants were defrauded by an individual on parole from a Utah prison. Appellants filed a complaint alleging causes of action against the State for negligent supervision, gross negligence, failure to warn, and negligent misrepresentation. Under the Governmental Immunity Act, the State is immune from a suit where the injury arises out of deceit. The district court dismissed the case based on the State's governmental immunity, finding that Appellants' injury was the result of a third-party's deceit. The Supreme Court affirmed, holding (1) the State was immune under the Utah Governmental Immunity Act's deceit exception; and (2) the dismissal of Appellants' complaint on the basis of governmental immunity was timely. View "Van De Grift v. State" on Justia Law

At issue in this case were two agreements: a ground lease agreement between ASC Utah, Inc. (ASCU) and Wolf Mountain Resorts, and a specifically planned area (SPA) development agreement, which had thirty-six signatories, including ASCU, Wolf Mountain, the D.A. Osguthorpe Family Partnership (Osguthorpe). ASCU and Wolf Mountain began litigating claims involving both the ground lease and the SPA agreement. Shortly thereafter, Osguthorpe sued ASCU and Wolf Mountain, alleging that each party had breached a land-lease agreement distinct from the ground lease or the SPA agreement. The district court consolidated Osguthorpe's separate actions into ASCU's litigation. Osguthorpe later moved to compel arbitration on all the claims related to the SPA agreement, including the claims between ASCU and Wolf Mountain, to which Osguthrope was not a party. The district court denied Osguthrope's motion. Osguthrope withdrew its SPA claims from the case, leaving for appeal only Osguthrope's motion to compel arbitration of the SPA claims between ASCU and Wolf Mountain. The Supreme Court affirmed, holding (1) the disputes for which Osguthrope sought to compel arbitration were not subject to the SPA agreement's arbitration provision; and (2) furthermore, as a non-party to the disputes, Osguthrope had no contractual right to compel their arbitration. View "Osguthorpe v. Wolf Mountain Resorts, L.C." on Justia Law

Defendant pled guilty to disorderly conduct in the justice county and was sentenced to ninety days in jail and ordered to pay a fine. After conducting a trial de novo, the district court convicted Defendant of the original charge, sentenced him to 180 days in jail, and imposed a higher fine. Defendant petitioned the court of appeals for extraordinary relief, arguing that the district court violated Utah Code 76-3-405 when it imposed a more severe punishment than the one originally imposed by the justice court. The court of appeals denied the requested relief, reasoning that although the statute generally prohibits the imposition of a greater sentence after a defendant appeals, Defendant's case fell outside of the general rule because his original conviction and sentence resulted from a plea agreement. The Supreme Court affirmed, holding that the section 76-3-405(2)(b) exception against imposing a harsher sentence on appeal when a defendant has entered into a plea agreement applies to justice court proceedings. View "Vorher v. Court of Appeals" on Justia Law

The Utah Highway Patrol performed a drug interdiction exercise on a rural stretch of the interstate. UHP chose to focus the bulk of its enforcement efforts on cars bearing out-of-state license plates. Defendant's California-plated vehicle was stopped during the exercise, and the traffic stop yielded evidence of illegal drugs. Defendant was charged with possession with intent to distribute. Defendant filed two suppression motions - one based on the Equal Protection Clause and right to travel and the other rooted in the Fourth Amendment. The district court denied both motions, and Defendant entered a conditional guilty plea. On appeal, the Supreme Court affirmed, holding (1) the traffic stop did not restrict Defendant's movement in a manner implicating his fundamental right to travel; (2) because there was a rational basis for UHP's selective enforcement of traffic laws - by choosing to stop vehicles licensed outside of Utah - Defendant's equal protection claim was meritless; and (3) to the extent the district court erred in failing to consider any evidence of relevance to the Fourth Amendment motion to suppress, it was harmless error. View "State v. Chettero" on Justia Law

Michael Howe, an employee of Peak Alarm Company, filed a complaint against the City and several of its employees, presenting ten federal and state claims, including false arrest and defamation. The district court granted summary judgment in favor of Defendants on these and other state claims on the ground that Howe failed to comply with the procedural requirements of the Utah Governmental Immunity Act (UGIA). The supreme Court reversed, holding that the claims were timely brought under the UGIA. On remand, Defendants again moved for summary judgment, arguing that the state defamation and false arrest claims were barred by the one-year statute of limitations. The district court denied the motion on the ground that the claims had been timely brought under the UGIA. The Supreme Court affirmed, holding that the UGIA comprehensively governs claims against governmental parties such that plaintiffs are not bound to observe the statute of limitations that would apply to claims against private parties. View "Peak Alarm v. Salt Lake City Corp." on Justia Law

Defendant, a passenger in a vehicle stopped for a traffic infraction, was arrested for possession of methamphetamine after being questioned and searched by a deputy sheriff. Defendant moved to suppress the fruits of the search. The district court denied the motion to suppress, and the court of appeals affirmed. Defendant appealed, arguing that the deputy improperly extended the length of the detention without reasonable suspicion that Defendant was engaged in criminal activity. The Supreme Court affirmed, holding (1) the deputy's questioning of Defendant, during which Defendant admitted to possession of illegal drugs, was proper based on the deputy's reasonable suspicion brought about by the driver's likely impairment and the presence of used drug paraphernalia in plain sight; and (2) the deputy did not improperly extend the duration of Defendant's detention because the deputy's single question to Defendant resulted in only a de minimis extension of the otherwise lawful detention. View "State v. Simons" on Justia Law

Defendant as convicted of aggravated murder and attempted aggravated murder. Defendant's conviction was affirmed on appeal, after which he filed a pro se petition seeking relief under the Post-Conviction Remedies act (PCRA) on the grounds that his trial counsel was ineffective for failing to raise a defense and that his appellate counsel was ineffective for failing to raise a claim of ineffective assistance of counsel on direct appeal. The court granted summary judgment for the State, concluding that Defendant's appellate counsel was not ineffective and that Defendant's ineffective assistance of trial counsel claim was procedurally barred. The Supreme Court reversed, holding (1) disputed issues of material fact precluded summary judgment on Defendant's claim that his appellate counsel was ineffective; and (2) because the Court could not determine whether appellate counsel was ineffective, it could not determine whether Defendant's claim regarding trial counsel was procedurally barred by the PRCA. Remanded for an evidentiary hearing. View "Ross v. State" on Justia Law