Archuleta v. Galetka
2011 UT 73
| Utah | 2011Background
- Archuleta was convicted of first-degree murder in 1989 and sentenced to death for the murder of Gordon Church in 1988.
- The crime involved torture and mutilation, including tire chains, a tire iron, and an attempted electrocution; Church’s body was found naked with restraints and a gag.
- Archuleta and codefendant Wood bound Church, transported him, and inflicted lethal and brutal injuries before discarding the body.
- Archuleta appealed his conviction and death sentence; this opinion consolidates analysis from multiple post-conviction proceedings and confirms the death sentence.
- Archuleta filed a petition for habeas relief challenging conviction and sentence, which the habeas court largely denied; Archuleta appealed those rulings.
- The Utah Supreme Court reviews these habeas corpus claims de novo for legal questions and reviews factual findings for clear error, upholding the trial court’s judgments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Procedural bar of substantive claims from Archuleta's petitions | Archuleta: first amended claims revived by Archuleta II; unusual circumstances justify airing | Galetka: substantive claims were procedurally barred; Archuleta II revived only ineffective-assistance claims | Thirty substantive claims remain procedurally barred |
| Effectiveness of trial/appeal counsel claims (Strickland analysis) | Archuleta: counsel failed to pursue mitigating evidence and key defenses | Galetka: no reasonable probability of different outcome; substantial evidence supported death | Most claims fail under Strickland; remaining mitigation claims lack prejudice showing |
| Ring v. Arizona impact on unanimity of aggravating factors | Archuleta: Ring requires unanimous, beyond-a-reasonable-doubt finding on each aggravator | Utah precedent did not require unanimity on individual aggravators; Ring only requires jury beyond-reasonable-doubt on aggravating facts that authorize death | Ring does not alter Utah’s sentencing framework; no reversible error |
| Rule 60(b) relief from judgment | Archuleta sought relief due to ineffective post-conviction counsel | District court denied relief; issues lack extraordinary circumstances or timeliness | Rule 60(b)(1) motion untimely; rule 60(b)(6) claims not established as extraordinary circumstances |
| Especially heinous aggravating factor and consciousness requirement | Archuleta contends consciousness of pain needed for ‘especially heinous’ | Utah law allows determination without requiring consciousness of pain during the attack | ‘Especially heinous’ does not require victim consciousness during the attack; upheld |
Key Cases Cited
- State v. Wood, 648 P.2d 71 (Utah 1982) (settles Wood framework for sentencing inquiry in capital cases)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
- Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (requires jury beyond a reasonable doubt on facts necessary to impose death; not all aggravators require unanimity in Utah)
- Carter v. Galetka, 44 P.3d 626 (Utah 2001) (death-penalty issues reviewed but not all argued on the merits; finality of certain rulings} ,{)