Justia Constitutional Law Opinion Summaries

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

The Supreme Court held that the strict compliance requirement of section 110 of Utah's Adoption Act, which permits a district court to terminate parental rights if the parent does not "fully and strictly comply" with the statutory requirements, as applied to Mother, is not narrowly tailored to achieve the State's compelling interest in prompt adoption proceedings.Mother gave birth to Child in 2010. Sometime thereafter, Child went to live with Adoptive Parents. In 2015, Adoptive Parents filed an adoption petition and served notice of the proceeding on Mother. The notice informed Mother that she had thirty days to file a motion to intervene or she would forfeit her parental rights in Child and would be barred from participating in the adoption proceeding. Mother attempted to intervene, but the district court struck her filing due to a procedural deficiency in the document and barred her from participating in the adoption proceeding. Mother filed a Utah R. Civ. P. 60(b) motion seeking relief from the order to strike, which district court denied. The Supreme Court reversed, holding that Mother's substantive due process rights were violated because section 110's strict compliance requirement is not narrowly tailored. View "In re K.T.B." on Justia Law

The Supreme Court affirmed Defendant's sentence of life in prison without the possibility of parole for aggravated murder, holding that Defendant was not entitled to a new penalty-phase trial.Specifically, the Supreme Court held (1) even if Defendant's trial counsel rendered ineffective assistance, Defendant was not prejudiced by that deficiency; (2) any error in admitting certain hearsay statements during trial was harmless beyond a reasonable doubt; (3) Defendant was not prejudiced by victim-impact evidence; (4) the trial court did not abuse its discretion by refusing to give a beyond-a-reasonable-doubt jury instruction under State v. Lafferty, 749 P.2d 1239 (Utah 1988); and (5) Defendant inadequately briefed his argument under the doctrine of cumulative error. View "State v. Drommond" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for being an accomplice to the crime of aggravated murder, holding that it was reasonably probable that the jury would not have convicted Defendant of aggravated murder absent jury instruction errors.After Defendant was convicted she appealed, arguing that her trial counsel was ineffective for failing to object to three errors in the jury instruction regarding accomplice liability. The court of appeals concluded that there were three errors in the jury instruction and that the performance of Defendant's trial counsel was deficient because he did not object to the errors. However, the court of appeals determined that the errors were not prejudicial because there was not a reasonable probability of a more favorable outcome absent the errors. The Supreme Court reversed and remanded the case for a new trial, holding (1) the jury instruction discussing the elements for accomplice liability on aggravated murder contained three errors; and (2) there was a reasonable probability that at least one juror would not have voted to convict Defendant in the absence of the errors. View "State v. Grunwald" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction for burglary and sexual abuse, holding that any error found or assumed in this case was not prejudicial.On appeal, Defendant argued that the prosecutor's comments about he differences between his initial statement at the scene of the crime and his trial testimony violated his constitutional right to remain silent and that the trial court's admission of two prior acts - a peeping incident and a trespassing incident - was prejudicial error. The Supreme Court affirmed, holding (1) assuming that a constitutional violation occurred during the prosecutor's cross-examination about omissions in Defendant's statement at the scene, the violation was harmless beyond a reasonable doubt and did not prejudice Defendant; (2) any assumed error in the admission of the trespassing incident was harmless; and (3) Defendant failed to preserve his challenge to the admission of the peeping incident. View "State v. Argueta" on Justia Law

The Supreme Court affirmed the opinion of the court of appeals affirming the judgment of the post-conviction court denying Petitioner's pro se petition under the Post-Conviction Remedies Act, Utah Code 78B-9-101 to -503, holding that Petitioner failed to identify a material dispute sufficient to rebut the State's showing that he was not prejudiced by his guilty plea or the State's showing that his trial counsel's performance was not deficient.Petitioner pled guilty to first-degree murder. In his post-conviction petition, Petitioner argued that his guilty plea was unknowing and involuntary because he did not understand that the absence of imperfect self-defense was an element of murder and that he received ineffective assistance of counsel because of a language barrier with trial counsel. The post-conviction court granted summary judgment in favor of the State, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) Petitioner's claim that his plea was unknowing and involuntary failed because there was no genuine issue of material fact as to whether he was prejudiced as a result; and (2) no genuine issue of material fact existed as to whether trial counsel's failure to obtain an interpreter constituted deficient performance. View "Arriaga v. State" on Justia Law

In this eminent domain action, the Supreme Court reversed the judgment of the district court endorsing a "general rule that a party may not rely on post-valuation facts and circumstances to prove severance damages," holding that there is no categorical rule foreclosing the relevance of evidence of a subsequent transaction involving the property in question.In 2009, a portion of Plaintiff's property was taken by the Utah Department of Transportation (UDOT). During the subsequent litigation, the parties disputed the amount of damages for the condemned property and on the amount of severance damages as to Plaintiff's remaining property. Plaintiff eventually sold the remaining property, which was developed into two car dealerships. On a pretrial motion in limine the district court excluded this development, concluding that that the property had to be valued as of the date of the taking and based on what a willing buyer and seller would have known at that time. The Supreme Court reversed, holding that there is no categorical rule deeming post-valuation-date evidence irrelevant to the determination of fair market value under Utah Code 78B-6-511 and -512. View "Utah Department of Transportation v. Boggess-Draper Co." on Justia Law

In this case brought by an alleged victim of child-sex abuse years after the alleged abuse occurred, the Supreme Court held that the Utah Legislature is constitutionally prohibited from retroactively reviving a time-barred claim in a manner depriving a defendant of a vested statute of limitations defense.Plaintiff, who alleged that Defendant sexually abused her in 1981, conceded that each of her claims had expired under the original statute of limitations. Plaintiff, however, argued that (1) her claims were revived when the legislature, in 2016, enacted Utah Code 78B-2-308(7), and (2) her claims against Defendant were timely filed under this statue. The federal court certified this case to the Supreme Court asking the Court to clarify whether the legislature had the authority to expressly revive time-barred claims through a statute. The Supreme Court held (1) the legislature lacks the power to retroactively vitiate a ripened statute of limitations defense under the Utah Constitution; and (2) therefore, section 78B-2-308(7) is an unconstitutional exercise of legislative power. View "Mitchell v. Roberts" on Justia Law