Menzies v. State
2014 UT 40
| Utah | 2014Background
- Menzies was convicted of first-degree murder in 1986 and sentenced to death.
- This appeal is Menzies’ second post-conviction proceeding under the PCRA, challenging funding, procedural rulings, and claims of ineffective assistance.
- The post-conviction court (PCC) denied the Fifth Amended Petition and granted the State’s summary judgment in 2012.
- Menzies challenged the PCRA funding provisions as unconstitutional and argued the PCC abused its discretion by denying further funding.
- The PCC rulings also addressed whether the State needed to answer the petition, whether a Rule 56(f) continuance or an evidentiary hearing was required, and whether trial/penalty/appellate counsel were ineffective.
- The Utah Supreme Court affirmed, holding that the PCRA funding limits were not unconstitutional, and that the procedural rulings and ineffective-assistance claims were properly resolved against Menzies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of PCRA funding | Menzies asserts a constitutional right to funded post-conviction counsel | State contends no constitutional right to such funding exists | Constitutionality rejected; no funded-right established; funding deemed reasonable |
| PCRA funding and discovery discretion | Funding requests for further investigation were necessary to support relief | PCC properly limited discovery as speculative/duplicative | PCC did not abuse discretion in denying further PCRA funding and discovery |
| Procedural posture of summary judgment | State must answer petition before moving for summary judgment; and he needed continuances/hearings | Rule 65C allows summary judgment in lieu of an answer; no mandatory continuance/hearing | Rule 65C permits summary judgment without an answer; no abuse in denying continuance/hearing |
| Ineffective assistance of counsel (guilt/penalty/appellate) | Counsel’s performance was deficient and prejudicial across trial, sentencing, and appeal | State showed no deficient performance or prejudice; decision supported by record | PCRA court’s grant of summary judgment affirmed; claims did not meet Strickland standard |
Key Cases Cited
- Rom(p)illa v. Beard, 545 U.S. 374 (Sup. Ct. 2005) (relevance of trial counsel’s investigation under Strickland guidelines; use of standards contemporaneous to trial)
- Cage v. Louisiana, 498 U.S. 39 (Sup. Ct. 1990) (unconstitutional reasonable doubt instruction; structural error considerations)
- Carter v. Galetka, 2001 UT 96, 44 P.3d 626 (Utah 2001) (standard for effective assistance in Utah capital cases; reasonable reliance on ABA/NLADA standards)
- Archuleta v. Galetka, 2011 UT 73, 267 P.3d 232 (Utah 2011) (ABA standards guiding Strickland analysis; later reaffirmed guidance on mitigation and investigation)
- Lenkart v. State, 2011 UT 27, 262 P.3d 1 (Utah 2011) (reasonableness of trial counsel’s investigation and strategy under Strickland; strong deference to counsel’s decisions)