The Utah Court of Appeals held that negligent charging delay did not violate the Sixth Amendment where claimed parole and plea consequences were speculative.
The Utah Supreme Court held that violating the rule governing nighttime warrant service does not itself require suppression without a constitutional violation, bad faith, or prejudice.
The Wyoming Supreme Court affirmed Steven Randall Marler’s convictions on eight counts of sexual abuse and six counts of battery against children in his care, holding that the district court properly admitted broad Rule 404(b) “other acts” evidence of grooming rituals and a fear-based disciplinary regimen, that a victim’s collateral lie to a jail guard was excludable without violating the Confrontation Clause, that a rule-of-completeness claim was waived by failure to make an offer of proof, and that brief prosecutorial questioning about a victim’s father’s suicide did not constitute plain-error misconduct.
Conviction reversed and new trial ordered: trial court required the People to give race-neutral reasons for peremptory challenges — implicitly finding a prima facie Batson case — then erroneously denied the challenge at step 1 without proceeding to pretext analysis at step 3.
Appellate Division affirms dismissal of weapons indictment after finding the DA’s Certificate of Compliance was invalid — failure to disclose police memo books and property vouchers constituted a lack of due diligence under CPL 245, triggering a speedy-trial violation under CPL 30.30.
The Appellate Division, Second Department sustained a habeas writ for a defendant held more than 90 days without a valid certificate of compliance, finding the People’s supplemental CoC deficient because 60-plus automatic discovery items—including mandatory impeachment materials—remained outstanding at the time of filing.
The Alaska Court of Appeals vacated Nick Frankson’s sentence because the State undermined its plea agreement and the trial judge failed to obtain Frankson’s personal decision to maintain his pleas.