Justia Constitutional Law Opinion Summaries

Defendant was convicted of aggravated sexual abuse of a child, a first-degree felony, and dealing in material harmful to a minor, a second-degree felony. Defendant appealed his convictions to the court of appeals, asserting he should be granted a new trial because his trial counsel was ineffective. Specifically, Defendant contended that trial counsel did not properly investigate or exploit discrepancies in the victim's statements about whether the abuse occurred in 2002 or 2003. The court of appeals agreed and granted a new trial on both charges. The State conceded that Defendant's counsel acted ineffectively in defending the sexual abuse conviction, but petitioned for writ of certiorari on the harmful materials conviction. The Supreme Court affirmed the court of appeals' conclusion that Defendant was entitled to a new trial on the harmful materials conviction, holding that trial counsel's failure to press the time discrepancy was prejudicial. Remanded. View "State v. Moore" on Justia Law

The State filed a petition that charge D.B. as a principal with theft and criminal trespass for entering a construction site and removing a pair of bolt cutters. The juvenile court adjudicated D.B. a delinquent as an accomplice on both counts. The court of appeals affirmed. D.B. filed a petition for writ of certiorari, claiming that he did not receive adequate Sixth Amendment notice that he may be adjudicated delinquent as an accomplice for the charges. The Supreme Court reversed the delinquency adjudication on the criminal trespass charge but affirmed it on the theft charge, holding (1) D.B. received constitutionally adequate notice through trial testimony that he faced accomplice liability for theft; but (2) the juvenile court adjudicated D.B. delinquent as an accomplice for criminal trespass without notice. Remanded. View "D.B. v. State" on Justia Law

Defendant was convicted of sexual abuse of a child. At trial, the court admitted evidence of two prior uncharged sexual assaults by Defendant. On appeal, Defendant challenged the admissibility of that evidence under Utah R. Evid. 404(b), asserting either that it was not offered for a non-character purpose or that its probative value was substantially outweighed by a risk of unfair prejudice. The court of appeals deemed the evidence admissible for two non-character purposes and affirmed. The Supreme Court (1) reversed the conviction, holding (i) the court of appeals erred in affirming the admissibility of evidence of Defendant's uncharged misconduct offered to prove his specific criminal intent, which was not a legitimately disputed issue at trial; and (ii) the State's evidence was not admissible to prove Defendant acted in conformity with a plan to entice and abuse young men, as the evidence did not demonstrate that Defendant entered a preconceived, overarching design to commit the acts in question; and (2) remanded for a new trial, leaving the door open for the State to offer its evidence on grounds different from those adopted by the trial court or court of appeals. View "State v. Verde" on Justia Law

Defendant was charged with possession of methamphetamine and drug paraphernalia after a search of his motel room. The district court declined to bind Defendant over for trial at a preliminary hearing, concluding that every reasonable inference from the evidence was that Defendant did not know of the presence of the drug residue and paraphernalia, and therefore, without evidence of an intent to exercise control, there could be no inference of possession of drug residue or paraphernalia. A divided court of appeals affirmed. The Supreme Court reversed, holding (1) the magistrate's and court of appeals majority's concerns with the evidence were insufficient to foreclose a finding of probable cause; (2) the magistrate and court of appeals overstepped their bounds in favoring Defendant's inference that he "didn't know the drugs were there" as stronger than the prosecution's alternative; and (3) the lack of evidence concerning the exclusivity of Defendant's control and access to the motel room did not defeat the prosecution's showing of probable cause. Remanded with instructions to bind Defendant over for trial.

Defendant was convicted of aggravated assault and criminal mischief. Defendant appealed his convictions and submitted a hybrid Anders/merits brief. Upon review of Defendant's pro se filings and his counsel's Anders brief, the court of appeals identified only one meritorious issue: the claim that the jury instructions misstated the law regarding aggravated the assault. The court of appeals then affirmed Defendant's conviction based on its interpretation of the aggravated assault statute. On certiorari before the Supreme Court, Defendant challenged the court of appeals' interpretation of the aggravated assault statute and advanced other claims foreclosed by the court of appeals' statutory interpretation. Court affirmed on alternate grounds, holding (1) the court of appeals erred in its interpretation of the statute; but (2) although counsel's failure to object to the instructions resulted in deficient performance, there was no prejudice to Defendant sufficient to justify reversal of the verdict.

The Supreme Court granted the State's petition for interlocutory review to address whether a court may grant a criminal defendant's request to waive a jury trial over the prosecution's objection. The district court granted Defendant's waiver of a jury trial in favor of a bench trial because of the court's perceived due process concerns. On appeal, the State argued that the district court erred because it disregarded the clear provisions of Utah. R. Crim. P. 17(c) that require the consent of the prosecution before a defendant may waive a jury trial. The Supreme Court reversed, holding (1) under Rule 17(c), Defendant may not waive a jury trial without the State's consent; and (2) Defendant's due process rights were not implicated in this case. Remanded for a jury trial.

Defendant was charged with aggravated murder and aggravated burglary. After being tried and convicted on both charges, he was sentenced to death. On appeal, Defendant raised numerous arguments concerning his convictions, the imposition of the death penalty, and Utah's death penalty scheme. Defendant's arguments included (1) jury issues, (2) evidence and arguments in the guilt phase of the trial, (3) challenges regarding the death penalty exemption hearing, (4) evidence and arguments in the penalty phase, (5) constitutional challenges to Utah's death penalty scheme, and (6) claims of cumulative error. The Supreme Court rejected each of Defendant's arguments and affirmed Defendants' convictions and sentence.

Stephen Maxfield challenged the results of the 2010 gubernatorial election under Utah's election-contest statute, asking the district court to declare him and his running mate the lieutenant governor and governor of Utah, respectively. The court dismissed the petition, concluding that the statutory grounds for an election contest did not encompass Maxfield's claims. The Supreme Court affirmed, holding (1) the district court did not err in disposing of the case by deciding Herbert's timely-filed Rule 12(b)(6) motion; (2) the nature of the hearing held in district court was appropriate, and Maxwell's right to a timely hearing was waived; and (3) the district court did not err in refusing to allow Maxfield to bring an election contest based on allegations of campaign finance violations.

A jury convicted Defendant of aggravated robbery. The jury found that Defendant was subject to a one-year enhancement of his sentence because a dangerous weapon was used in the course of the robbery. The court of appeals affirmed. Defendant appealed, contending that the State failed to prove he had knowledge of the principal's possession of a dangerous weapon. The Supreme Court affirmed the conviction of aggravated robbery with a one-year penalty enhancement after clarifying the mental state required for the dangerous weapon aggravator in Utah Code 76-6-302(1)(a), holding (1) because the legislature has made no indication that it is a strict liability offense, the statutory aggravator requires the culpable mental state of recklessness; but (2) Defendant's claims on appeal did not require reversal because he did not demonstrate that the errors caused him prejudice.

Plaintiffs brought suit against a law firm and its attorneys for their role in executing civil discovery orders. The orders authorized entry into Plaintiffs' home to seize electronic files from Plaintiffs' computer and other electronic devices. Plaintiffs raised several causes of action based largely on the theory that the execution of the civil discovery orders constituted an illegal warrantless search. The district court granted Defendants' motion for judgment on the pleadings, and the court of appeals affirmed. The Supreme Court affirmed on alternate grounds, holding (1) the judicial proceedings privilege extends to attorneys' conduct in representing their clients; and (2) as applied in this case, the privilege barred all of Plaintiffs' claims.