Kamoe v. Hon. Ridge, 483 P.3d 720

Alexie Kamoe was charged in Utah County Justice Court with three offenses; she pleaded guilty pursuant to a negotiated plea to a single count of Impaired Driving and received a suspended jail sentence, fines, and treatment conditions.
Kamoe appealed her justice-court conviction to the district court; the justice court stayed her sentence under Utah Code § 78A-7-118(2).
In district court Kamoe again moved to suppress blood-test evidence, the motion was denied, and she withdrew her appeal and asked for remand to the justice court under Utah R. Crim. P. 38(f)(6).
Back in justice court Kamoe asked the court to lift the stay and reinstate the original judgment; the prosecutor objected, claiming § 78A-7-118(3) voided the negotiated plea judgment upon appeal, and the justice court denied reinstatement.
Kamoe petitioned the district court for extraordinary relief under Utah R. Civ. P. 65B(d)(2); the district court denied relief; Kamoe appealed to the Utah Supreme Court.

Issue	Plaintiff's Argument (Kamoe)	Defendant's Argument (State)	Held
Does an appeal from a negotiated guilty plea in justice court under § 78A-7-118(3) void the justice-court judgment?	Appeal does not void the judgment; judgment persists (may be stayed) unless vacated or replaced by the district court.	The statute voids the negotiated plea and therefore voids the conviction, sentence, and commitment on appeal.	The Court held an appeal does not void the justice-court judgment; the judgment persists and may be stayed pending appeal.
What does the word “negotiation” in § 78A-7-118(3) mean?	Means the pre-plea agreement between prosecutor and defendant (i.e., the bargaining agreement), not the court’s judgment.	Includes the plea, sentence, and judgment—that is, the negotiated outcome.	The Court held “negotiation” refers to the pre-plea agreement; it does not include the judgment.
Is extraordinary relief under Rule 65B(d)(2) appropriate to correct the lower courts’ misapplication?	Yes; justice court misapplied the statute and abused its discretion, so relief should be granted to reinstate the judgment.	No; granting relief would incentivize strategic appeals and destabilize the justice-court system.	The Court exercised its discretion to grant relief, reversed the district court, and remanded with instructions to reinstate the original judgment.

State v. Barrett, 127 P.3d 682 (Utah 2005) (abuse-of-discretion review and factors for extraordinary relief under rule 65B)
State v. Sery, 758 P.2d 935 (Utah Ct. App. 1988) (describing conditional/Sery pleas that reserve suppression issues on appeal)
Bernat v. Allphin, 106 P.3d 707 (Utah 2005) (explaining uniqueness of de novo appeals from justice court)
Vorher v. Henriod, 297 P.3d 614 (Utah 2013) (discussing effect of guilty pleas on sentencing limits on appeal)
State v. Petersen, 810 P.2d 421 (Utah 1991) (trial courts cannot misapply the law without abusing discretion)
State v. Ogden, 416 P.3d 1132 (Utah 2018) (statutory interpretation principles; reliance on plain language)