Justia Constitutional Law Opinion Summaries
Articles Posted in Utah Supreme Court
State v. Moa
This appeal encompassed two consolidated cases. In the first case, Charles Moa entered a no contest plea to a third degree felony but later filed motions to withdraw that plea. Moa first stipulated that his plea was taken in compliance with Utah R. Crim. P. 11 but, on appeal, argued that his plea was not taken in compliance with Rule 11. The court of appeals held that Moa failed to demonstrate plain error in the district court's denial of his motions. In the second case, Moa pled guilty to two felonies and a misdemeanor. The sentencing judge imposed consecutive sentences. The court of appeals affirmed, rejecting Moa's argument that the sentencing judge relied on irrelevant information in imposing the sentences. The Supreme Court affirmed, holding (1) in the first case, by stipulating that his plea was taken in compliance with Rule 11, Moa invited any error that may have been committed by the district court; and (2) in the second case, the court of appeals was correct in concluding that there was no evidence that the district court relied on any improper information in imposing consecutive sentences.
State v. Alexander
James Alexander pled guilty to burglary with intent to commit sexual battery. Prior to sentencing, Alexander filed a timely motion to withdraw his guilty plea, arguing (1) the district court failed to apprise him of the elements of sexual battery as required by Utah R. Crim. P. 11, and (2) his plea was not knowingly and voluntarily made. The court denied Alexander's motion and sentenced him accordingly. The court of appeals reversed, concluding (1) the district court did not comply with Rule 11 at the plea hearing because it did not inform Alexander of the elements of sexual battery, and (2) the violation of Rule 11 rendered the plea unknowing and involuntary. The Supreme Court affirmed, holding (1) although the court of appeals erred in limiting its review to whether the district court had complied with Rule 11 during the plea hearing, the record demonstrated that Alexander's plea was not knowingly and voluntarily made; (2) the court of appeals did not err in declining to require a showing of prejudice; and (3) because this case involved a different issue than the one addressed in the Court's holding in Hurst v. Cook, the two cases did not conflict.
Kell v. State
Troy Kell was convicted of murder and sentenced to death. Kell subsequently filed a petition for postconviction relief, alleging ineffective assistance of trial counsel, which the district court dismissed. The Supreme Court affirmed. Kell thereafter filed a Utah R. Civ. P. 60(b) motion, asking the district court to relieve him from its earlier dismissal of his petition for postconviction relief. The district court denied the motion, holding that because Kell's postconviction petition had been dismissed, appealed, and affirmed on appeal, the underlying denial of his petition for postconviction relief was no longer "pending" and thus the court could not consider the merits of the 60(b) motion. The Supreme Court affirmed on alternate grounds, holding (1) Rule 60(b) does not have a "pending" requirement and is not necessarily inappropriate in all cases in which the Court has already ruled, but it may not be used as a way to circumvent the Post-Conviction Remedies Act (PCRA); and (2) in this case, Kell's claims were barred by the PCRA and therefore could not be brought under Rule 60(b).
Mellor v. Wasatch Crest Mut. Ins.
Plaintiff's son, Hayden, was involved in a near-drowning accident in which he suffered severe permanent injuries. Plaintiff subsequently sought coverage for the cost of his treatment from Wasatch Crest Mutual Insurance, under which Hayden was insured. Wasatch Crest was later declared insolvent, and Plaintiff filed a claim against the Wasatch Crest estate. The liquidator of the estate denied Plaintiff's claim, concluding that Wasatch Crest had properly terminated coverage under the language of the plan. The Supreme Court reversed, interpreting the plan in favor of coverage. Plaintiff resubmitted her claim for medical expenses to the liquidator for payment under the Utah Insurers Rehabilitation and Liquidation Act. One year later, Plaintiff filed a motion for summary judgment with the district court. The liquidator subsequently issued a second amended notice of determination denying Plaintiff's claim on the merits. The district court then denied Plaintiff's motion for summary judgment, as Plaintiff had not yet challenged the second amended notice of determination and could do so under the Liquidation Act. Plaintiff appealed the district court's order. The Supreme Court dismissed the appeal because Plaintiff did not appeal from a final judgment and had not satisfied any of the exceptions to the final judgment rule.
State v. Prion
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.
Whitney v. Div. of Juvenile Justice Servs.
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.
State v. Price
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.
Taylor v. State
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.
State v. Harding
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.
State v. J.M.S.
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.