Justia Constitutional Law Opinion Summaries

Lemuel Prion pled guilty and mentally ill to three felony charges pursuant to Utah Code Ann. 77-16-104(3). Under the provisions of the statute, Prion was first sentenced to three terms of varying length, all to be served concurrently. As part of his first sentence, Prion was committed to the hospital for evaluation. After his stay there, Prion was released. Based upon the recommendations of the hospital staff and administration, the district court resentenced Prion to serve his three terms consecutively, nearly doubling his prison time. Prion filed a motion to correct his sentence, claiming that his second sentence was statutorily barred and violated the Double Jeopardy Clause of the federal constitution. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed and remanded, concluding that, although the sentencing statute at issue expressly allows for a recall and resentencing at any time during an eighteen-month review period, Prion's resentencing exceeded the bounds of the double jeopardy clause in light of the nature and timeframe of this proceeding.

Dillon Whitney's mother filed a wrongful death suit against the State after Dillon died while in state custody. The State filed a motion to dismiss, arguing that it was exempt from suit under the incarceration exception to the Governmental Immunity Act of Utah. The federal district court denied the motion, and the State appealed. The Supreme Court accepted certification to answer a question of state law and held (1) a juvenile who is placed in an unsecured community-based proctor home is not incarcerated in a place of legal confinement; and (2) accordingly, the incarceration exception to the State's waiver of its sovereign immunity did not apply in this case, and the State remained potentially liable for damages related to Dillon's death.

While driving, Jed Price struck another vehicle, killing a passenger in that vehicle. After he consented to accompany an officer to a police station, a magistrate issued a warrant to seize Price's blood for testing to determine his blood-alcohol levels. The blood was tested for the presence of, among other things, THC, and the test results came back positive for the presence of THC. Price was subsequently charged with causing death while driving with a measurable controlled substance and failing to yield the right of way. The district court denied Price's motion to suppress the evidence. Price appealed, arguing that testing for THC was outside the scope of the warrant because the magistrate's probable cause determination was based only on the suspicion that Price had been driving under the influence of alcohol. The Supreme Court affirmed, holding (1) after his blood was lawfully obtained, Price did not have a reasonable expectation of privacy in any contraband in his blood; (2) the test for THC did not infringe on any legitimate privacy interests; and (3) the testing was therefore constitutional.

Von Lester Taylor pled guilty to two capital homicide charges and was sentenced to death. A Utah R. App. P. 23B hearing was later held before the district court, after which the court rejected all of Taylor's claims of ineffective assistance of trial counsel. The Supreme Court affirmed. Taylor's counsel thereafter filed a petition for post-conviction relief, which the district court denied. The Supreme Court affirmed. Taylor then filed a successive petition for post-conviction relief. The district court granted the State's motion to dismiss the petition, holding that all of Taylor's claims were procedurally barred under the Post-Conviction Remedies Act (PCRA) because they were raised, or could have been, but were not, raised in a prior proceeding. The Supreme Court affirmed, holding that Taylor failed to establish that his claims could not have been raised in a prior proceeding and failed to meet any statutory or common law exceptions to the procedural bar.

Tina Harding was one of three passengers in a vehicle that was stopped by a law enforcement officer. The driver gave the officer her consent to search the vehicle. Without inquiring about who owned them, the officer proceeded to search two backpacks and bags found in the vehicle. The officer found drugs and paraphernalia in the backpacks, which belonged to Harding. Harding subsequently entered a conditional guilty plea to methamphetamine possession and possession of a dangerous weapon by a restricted person. The court of appeals affirmed. Harding appealed, asserting that the officer had improperly assumed the driver had authority to consent to the search of her backpacks. The Supreme Court concluded (1) the evidence adduced in the district court supported the conclusion that the officer could not have reasonably believed that the driver had authority to consent to a search of Harding's backpacks; but (2) the district court did not make any particularized findings as to whether Harding's conduct in relation to the search suggested the driver had apparent authority to consent to a search of her backpacks or as to the general nature of the backpacks searched by the officer. Remanded for further factual findings.

The State filed a delinquency petition alleging that a seventeen-year-old girl had engaged in criminal solicitation to commit murder after she asked a stranger to punch her in the stomach to terminate her pregnancy. The juvenile court (1) held that an assault of a woman by punching her in the stomach was a "procedure" intended to terminate her pregnancy and therefore qualified as an abortion under statute; and (2) dismissed the State's petition against the minor because a woman cannot be held criminally liable for seeking an abortion. The Supreme Court reversed, holding that the solicited assault of a woman to terminate her pregnancy was not a "procedure" as contemplated by statute and therefore did not constitute an abortion. Remanded.

Defendant pleaded guilty to attempted murder of the unborn child of a juvenile mother. The charge and plea were based on the allegation that Defendant tried to kill the child by punching Mother in the abdomen in exchange for a payment by Mother. At Defendant's sentencing, the district court sua sponte found him ineligible for conviction of attempted murder under the standard set forth in State v. Shondel and sentenced him instead to the lesser charge of attempted killing an unborn child by abortion. The Supreme Court reversed, holding (1) the State had a statutory right of appeal from the district court's holding because the court implemented the decision to effect a "final judgment of dismissal" of the murder charge; (2) the Court's reconsideration of the district court's decision did not raise double jeopardy concerns because a reversal would not subject Defendant to successive prosecution but merely reinstate Defendant's guilty plea on the attempted murder charge; and (3) there was no Shondel bar to Defendant's sentencing on the charge of attempted murder because the elements of attempted murder differ from the elements of attempted killing of an unborn child by abortion.

Michael Archuleta was convicted of first degree murder and sentenced to death. This opinion consolidated analysis from the fourth and fifth times the Supreme Court entertained appeals by Archuleta. The Supreme Court reaffirmed Archuleta's conviction and sentence, holding (1) the habeas court properly found that Archuleta's substantive challenges to his conviction and sentence were procedurally barred, and the habeas court correctly determined that Archuleta could not demonstrate his counsel rendered ineffective assistance under Strickland v. Washington; and (2) the district court did not abuse its discretion in denying Archuleta's Utah R. Civ. P. 60(b) motion because (i) Archuleta's rule 60(b)(1) motion was time-barred, and (ii) rule 60(b)(6)'s provision stating that judgment will be set aside for "any other reason justifying relief from the operation of the judgment" applies only in extraordinary circumstances not presented in this case.

Victor Hernandez was charged with four Class A misdemeanor offenses. Hernandez filed a request for a preliminary hearing. The district court denied Hernandez's request because it concluded that the right to a preliminary hearing under Utah Const. art. I, 13 did not apply to Class A misdemeanors. The Supreme Court reversed the decision of the district court, holding (1) article I section 13 grants the right to a preliminary hearing for indictable offenses, including Class A misdemeanors; and (2) because Hernandez was charged with Class A misdemeanors, the district court erred in not granting his request for a preliminary hearing. Remanded.

Terry Johnson was convicted of murdering his child's babysitter. The court of appeals affirmed. Johnson subsequently filed a petition for postconviction relief, challenging, among other things, his counsel's effectiveness and the sufficiency of the evidence supporting his conviction. The district court denied the petition without reaching the merits of Johnson's claims, finding each claim was either previously adjudicated, frivolous, or barred under the Post-Conviction Remedies Act. The Supreme Court affirmed, holding that because Johnson's petition contained claims that had been previously adjudicated, that the district court had no jurisdiction to decide, and that could have been, but were not, raised on direct appeal, the district court correctly dismissed Johnson's petition.