Justia Constitutional Law Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction of aggravated robbery, holding that the trial court did not plainly err in its handling of the State's reports of a sleeping juror and that defense counsel did not provide ineffective assistance.On appeal, Defendant asserted that he was denied his Sixth Amendment right to a jury trial because at least one juror allegedly slept during the proceedings. The court of appeals concluded that Defendant failed to demonstrate that the trial court plainly erred in declining to inquire into the attentiveness of the juror and that Defendant failed to demonstrate that his trial counsel provided ineffective assistance in responding to observations that the juror may have been sleeping. The Supreme Court affirmed, holding (1) a trial court should respond to a report of an inattentive or drowsy juror in a manner that is proportional to the report before it, but the trial court in this case did not plainly err in its response; and (2) Defendant failed to show that his counsel's actions were deficient. View "State v. Marquina" on Justia Law

The Supreme Court reversed the judgment of the district court denying a civil stalking injunction sought by Kristi Ragsdale against George Fishler, holding that the district court erred.Ragsdale ran Eva Carlton Academy (ECA), a residential treatment program for young women, out of her home in a suburb. Fishler, Ragsdale's neighbor, expressed his objection to ECA's presence in the neighborhood by flipping off and swearing at Ragsdale and others entering or exiting ECA and by placing provocative signs in his yard. The district court denied Ragsdale's request for an injunction. The Supreme Court reversed on each issue raised by Ragsdale and vacated the district court's ruling on Fishler's fee request, holding that the district court erred by (1) concluding that Fishler's conduct was directed only at ECA; (2) failing to determine whether Fishler's conduct would cause a reasonable person in Ragsdale's circumstances to suffer fear or emotional distress; and (3) denying Ragsdale's injunction on the ground that the First Amendment protects Fishler's conduct. Because the Court's reversal of these issues may affect the basis for the district court's denial of Fishler's attorney-fees request, the Court vacated that decision and remanded for a new determination. View "Ragsdale v. Fishler" on Justia Law

The Supreme Court affirmed the decision of the Labor Commission awarding Appellant permanent partial disability under the Workers' Compensation Act (WCA), Utah Code 34A-2-101 to -1005, holding that the Commission's process for determining permanent partial disability benefits is constitutional and that the administrative law judge (ALJ) was not permitted to increase the amount of the award based on Appellant's subjective pain.Based on Commission guidelines, the ALJ based the amount of Appellant's award on a report provided by an assigned medical panel. Appellant argued on appeal that the process for determining permanent partial disability benefits was unconstitutional and that the ALJ erred in failing to augment the medical panel's impairment rating by three percent, resulting in an increased compensation award. The Supreme Court disagreed, holding (1) the adjudicative authority of ALJs has not been unconstitutionally delegated to medical panels; and (2) the Commission expressly precludes ALJs from augmenting an impairment rating based on a claimant's subjective pain. View "Ramos v. Cobblestone Centre" on Justia Law