Justia Constitutional Law Opinion Summaries

The Supreme Court in this criminal case repudiated the sweeping language of its opinion in State v. James, 13 P.3d 576 (Utah 2000), and held that it can no longer be said that it makes no constitutional difference, as regards community caretaking concerns, whether a police officer opens a car door or asks a driver to do so.Defendant was charged with felony DUI and possession of drugs and drug paraphernalia. Defendant moved to suppress the evidence discovered after an officer looked inside his pickup truck, which was parked in a store parking lot, opened the truck door, and saw evidence of drug paraphernalia between Defendant's feet. The district court denied the motion. The court of appeals affirmed on alternative grounds, holding that the officer was justified in opening the car door incident to a lawful traffic stop under the standard in James. The Supreme Court affirmed, holding (1) the identity of the door-opener may well affect the reasonableness of a given police encounter; and (2) the denial of Defendant's motion to suppress was proper under the authority of Davis v. United States, 564 U.S. 229 (2011). View "State v. Malloy" on Justia Law

The Supreme Court affirmed Defendant's conviction of dealing in material harmful to a minor, a third degree felony under Utah Code 76-10-1206, holding that Defendant's argument that the statute was unconstitutional as applied failed.As part of a sexually explicit online chat, Defendant sent photographs of women with nude breasts to someone who he thought was an underage girl. Defendant was convicted of dealing in material harmful to a minor, in violation of section 76-10-1206. On appeal, Defendant argued that because the photographs he sent did not depict sexual activity they could not qualify as obscenity, and therefore, the photographs were protected speech under the First Amendment. The Supreme Court affirmed, holding that where nudity may be obscene to minors without depicting sexual conduct, Defendant's argument that the statute was unconstitutional as applied to his conduct failed. View "State v. Watts" on Justia Law

The Supreme Court affirmed Defendant's conviction of distribution of or arranging to distribute a controlled substance, holding that the trial court did not err in denying Defendant's challenge brought under Batson v. Kentucky, 476 U.S. 79 (1986) and that sufficient evidence supported the conviction.On appeal, Defendant argued that the State violated his right to equal protection when it used a peremptory strike to remove the only person of color from the jury pool. The trial court denied Defendant's Batson challenge, and the jury subsequently convicted him of drug-related counts. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's Batson challenge; and (2) there was sufficient evidence to support Defendant's conviction. View "State v. Aziakanou" on Justia Law

The Supreme Court affirmed the decision of the court of appeals ruling that the Post-Conviction Remedies Act (PCRA), Utah Code 78B-9-101-110, barred Appellant's claims because they "could have been" brought on appeal, holding that Appellant's claims failed because trial counsel was not ineffective.Appellant was convicted of sexually molesting his daughter. The convictions were affirmed on appeal. Appellant later filed a petition for post-conviction relief, arguing that his trial counsel was ineffective and that his appellate counsel was ineffective for failing to raise ineffectiveness claims on direct appeal. The reviewing court denied relief. The court of appeals affirmed, ruling that the PCRA barred Appellant's claims. The Supreme Court affirmed, holding (1) the PCRA barred Appellant's direct claims against his trial counsel; and (2) appellate counsel was not ineffective. View "McCloud v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of distributing or arranging to distribute a controlled substance, holding that Defendant's trial counsel was not constitutionally deficient in not requesting a jury instruction pursuant to State v. Long, 721 P.2d 483 (Utah 1986), about the potential unreliability of eyewitness identification.During trial, Defendant's counsel presented a theory of mistaken identification in his opening and closing arguments and cross-examined the prosecution's witnesses about weaknesses in their testimony. On appeal, Defendant argued that his trial counsel's failure to request a Long instruction constituted ineffective assistance of counsel. The court of appeals affirmed, concluding that Long does not apply to "real-time identifications," such as the identification in this case. The Supreme Court vacated the court of appeals' holding that Long did not apply but nevertheless affirmed, holding (1) the court of appeals erred when it ruled that Long applies only to "memory-based" identifications; and (2) a reasonable, competent lawyer could have chosen not to request a Long instruction in this case. View "State v. Hunter" on Justia Law

The Supreme Court affirmed the decision of the court of appeals rejecting Defendant's claim for ineffective assistance of counsel, holding that a factfinder may consider extrinsic evidence of the sexual purpose of a person charged with producing a visual depiction of murder.Defendant was convicted of thirty-three counts of child sex crimes, including aggravated sexual abuse of a child and forcible sodomy of a child. On appeal, Defendant argued that the trial counsel was ineffective based on his failure to object to the prosecutor's request that the jury consider Defendant's subjective intentions in deciding whether Exhibits 21 and 22 - two photographs obtained from Defendant's laptop - qualified as child pornography under Utah law. The court of appeals concluded that Defendant had asserted a successful claim for ineffective assistance of counsel with respect to Exhibit 22 but not Exhibit 21 and reversed Defendant's conviction based on Exhibit 22. The Supreme Court affirmed, holding that Defendant did not identify a basis for challenging the State's invitation for the jury to consider Defendant's subjective intention in creating an image that qualified as child pornography as a depiction of child nudity for the purpose of sexual arousal under Utah Code 76-5b-103(10)(f). View "State v. Jordan" on Justia Law

The Supreme Court vacated the decision of the district court concluding that the adjudication of Plaintiff's intentional infliction of emotional distress claim against a church must be dismissed on the grounds that the adjudication of this claim would violate the Establishment Clause of the First Amendment, holding that recent changes in the Supreme Court's Establishment Clause jurisprudence required further development of the facts and legal arguments presented in this case.Plaintiff and her family attended the Roy Congregation of the Jehovah's Witnesses Church. When Plaintiff was sexually assaulted by another Jehovah's Witnesses congregant the Church investigated Plaintiff to determine whether she had engaged in the sin of "porneia." During the investigation, four Elders in the Church convened a disciplinary hearing in which they played an audio recording of the other congregant raping Plaintiff. Plaintiff then filed her complaint against the Church for intentional or negligent infliction of emotional distress. The district court dismissed the complaint, concluding that the Establishment Clause barred the claim. The Supreme Court vacated the district court's decision, holding that because the district court relied on a test that has recently been displaced by the Supreme Court, the case must be remanded for additional proceedings. View "Williams v. Kingdom Hall of Jehovah's Witnesses" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the denial of post conviction relief sought by Defendant, holding that Defendant's claims failed.Defendant was convicted of sexually molesting his daughter. The convictions were affirmed on appeal. Defendant then filed a petition for post-conviction relief, asserting ineffective assistance of counsel. The reviewing court concluded that the Post-Conviction Remedies Act (PCRA), Utah Code 78B-9-101-110, barred Defendant's claims of ineffective assistance of trial counsel but allowed Defendant's ineffective assistance of appellate counsel claims to proceed. The court then denied relief. On appeal, the court of appeals held (1) the PCRA barred Defendant's "direct" claims, and (2) appellate counsel was de facto not ineffective. The Supreme Court affirmed, holding (1) the PRCA barred Defendant's direct claims against his trial counsel; and (2) Defendant's ineffective assistance of appellate counsel claims were without merit. View "McCloud v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to reinstate his right to appeal, holding that this Court lacked appellate jurisdiction.Defendant was convicted and sentenced for child sodomy and child sex abuse. Several appellate proceedings later, Defendant filed this motion seeking to reinstate his appeal. The district court denied the motion and denied Defendant's invitation to strike down Utah's Plea Withdrawal Statute, Utah Code 77-13-6, as unconstitutional. The Supreme Court affirmed, holding that criminal defendants cannot raise untimely or unpreserved challenges through a Manning-like motion. View "State v. Brown" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony driving under the influence (DUI) and possession of drugs and drug paraphernalia, holding that the exclusionary rule does not apply where law enforcement relied reasonably on then-existing precedent.In affirming Defendant's conviction, the court of appeals held that the police had the reasonable suspicion necessary to temporarily detain Defendant in his vehicle and ask him to step out of it. The Supreme Court affirmed, holding (1) this Court repudiates the sweeping language of its opinion in State v. James, 13 P.3d 576 (Utah 2019), and holds that the identity of the opener of a car door may affect the reasonableness of any given police encounter; but (2) the evidence here was not subject to exclusion because the police acted objectively reasonably in reliance on the Supreme Court's opinion in James. View "State v. Malloy" on Justia Law