State v. Allgier
2011 UT 47
| Utah | 2011Background
- In 2007, Allgier allegedly escaped after taking a gun from a corrections officer and killing the officer, leading to multiple serious charges.
- In May 2008, Brent Cobb, an inmate, wrote a letter asserting Allgier verbally admitted to the killing and detailed other claims, which the court provisional sealed.
- The district court allowed media intervention to oppose sealing and later granted unsealing of the Cobb Letter but kept contents sealed pending interlocutory appeal.
- Allgier petitioned for interlocutory appeal arguing the column letter was not entitled to a presumptive UCJA public access right and could be sealed to protect his fair-trial rights.
- The Media argued the Cobb Letter is a court record with a presumptive public access right under UCJA, and that unsealing would not prejudice Allgier’s fair trial given existing public information.
- The Court ultimately held that the Cobb Letter qualifies for a presumptive UCJA public-access right and Allgier failed to overcome that right, affirming unsealing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Cobb Letter has a presumptive UCJA public-access right. | Allgier: Letter not a UCJA-record with presumptive access. | Media: Letter is a court record under UCJA with presumptive access. | Yes; the Cobb Letter qualifies for a presumptive UCJA public-access right. |
| Whether Allgier rebutted the presumptive UCJA public-access right. | Allgier: unsealing would harm fair trial; presumption overrides sealing. | Media: existing public information mitigates fair-trial risk; sealing not justified. | No; Allgier failed to overcome the presumption; unsealing upheld. |
Key Cases Cited
- State v. Archuleta, 857 P.2d 234 (Utah 1993) (right not absolute; balancing allowed under UCJA)