Archuleta v. State, 472 P.3d 950

Background

In 1989 Michael Archuleta was convicted of first-degree murder and sentenced to death; his conviction and sentence survived direct appeal and multiple post-conviction proceedings.
Archuleta filed successive state habeas/post-conviction petitions (1994, 2002) and a rule 60(b) motion; this Court resolved those matters in Archuleta I–III.
In 2012 Archuleta filed federal habeas alleging he is intellectually disabled under Atkins v. Virginia; the federal court stayed proceedings and permitted him to exhaust an Atkins claim in state court.
In 2014 Archuleta filed a third state post-conviction petition asserting an Atkins claim plus twelve additional claims unrelated to Atkins. The post-conviction court granted summary judgment against him, concluding the PCRA barred his Atkins and other claims.
The Utah Supreme Court held that no provision of the Post-Conviction Remedies Act (PCRA) actually authorizes relief for an Atkins as-applied claim (so the claim is not cognizable under the PCRA), rejected Archuleta’s request for a common-law remedy as unripe, and affirmed that the twelve non-Atkins claims are procedurally barred.

Issues

Issue	Plaintiff's Argument (Archuleta)	Defendant's Argument (State)	Held
Whether Archuleta’s Atkins as-applied claim is cognizable under the PCRA	Section 78B-9-104(1)(a) (constitutional violation) allows relief for Atkins	PCRA §104(1)(f)(ii) (new rule decriminalizing conduct) or other PCRA provisions should cover retroactive substantive rules/status exemptions	Court: No PCRA provision plainly applies to an Atkins as-applied status exemption; the PCRA does not provide a remedy for this claim (not cognizable under the statute)
Whether PCRA time/procedural bars preclude Atkins claim and whether that makes the statute an unconstitutional suspension of habeas	If PCRA bars claim and leaves no remedy, it suspends habeas and Court should craft common-law equitable relief	PCRA bars apply and would preclude untimely/unchallenged claims	Court: Did not decide PCRA bars issue; because claim is not cognizable under PCRA, the Court did not find PCRA suspends the writ; constitutional challenge is premature
Whether Rule 22(e) (motion to correct sentence) supplies an alternative vehicle for Atkins relief and whether Archuleta’s constitutional challenge is ripe	Archuleta contends lack of other remedies makes PCRA unconstitutional and requests equitable relief	State contends PCRA and timing rules govern; Rule 22(e) inapplicable per State and prior cases	Court: Archuleta has not pursued Rule 22(e); his request for common-law relief is unripe — Rule 22(e) remains a possible avenue and PCRA excludes Rule 22(e) motions from its limits
Whether the twelve non-Atkins claims are procedurally/time barred under the PCRA	Archuleta says he added claims to exhaust them in state court and to develop facts	State argues most claims were previously litigated or could have been raised earlier	Court: All twelve claims are procedurally barred (ten previously litigated; the remaining two could have been raised years earlier)

Key Cases Cited

Atkins v. Virginia, 536 U.S. 304 (2002) (holding execution of intellectually disabled persons unconstitutional)
Penry v. Lynaugh, 492 U.S. 302 (1989) (prior Supreme Court precedent allowing execution of intellectually disabled persons, later abrogated by Atkins)
Teague v. Lane, 489 U.S. 288 (1989) (retroactivity framework distinguishing substantive from procedural new rules)
Montgomery v. Louisiana, 577 U.S. 190 (2016) (recognizing that some new substantive rules apply retroactively, including status-based exemptions)
Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance of counsel)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecutorial duty to disclose exculpatory evidence)
Gregg v. Georgia, 428 U.S. 153 (1976) (upholding constitutionality of death penalty under Eighth Amendment precedent)
State v. Archuleta, 850 P.2d 1232 (Utah 1993) (Archuleta I) (direct-appeal decision addressing evidentiary and sentencing issues)
Archuleta v. Galetka, 960 P.2d 399 (Utah 1998) (Archuleta II) (post-conviction remand on ineffective assistance issues)
Archuleta v. Galetka, 267 P.3d 232 (Utah 2011) (Archuleta III) (denying rule 60(b) relief; resolving many prior PCRA claims)
State v. Houston, 353 P.3d 55 (Utah 2015) (construing applicability of Rule 22(e) and PCRA restrictions)