State v. Greenwood
297 P.3d 556
Utah2012Background
- Jamie Lynn Greenwood was charged with five felonies: two rape counts, two forcible sodomy counts, and one forcible sexual abuse count.
- Greenwood requested a bench trial, citing concerns that a jury would be less objective due to the charges and publicity.
- The State objected, arguing rule 17(c) requires prosecution consent before a jury waiver and that the district court must deny the waiver.
- The district court granted Greenwood's waiver, forcing a bench trial over the State's objection, citing due process concerns.
- The State appealed via emergency stay and interlocutory review; the Utah Supreme Court held rule 17(c) controls and reversed for a jury trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court erred in granting a bench trial over the State's objection | Greenwood | State | Yes; district court erred in not enforcing rule 17(c). |
| Whether Greenwood's due process rights were implicated by denying a jury trial | Greenwood | State | No; due process rights not implicated at this stage. |
| Whether the court should defer to district court as a mixed question of law and fact | Greenwood | State | No; legal questions reviewed for correctness; rule 17(c) governs waiver. |
Key Cases Cited
- Singer v. United States, 380 U.S. 24 (1965) (no constitutional right to bench trial; waiver may be conditioned on prosecution consent)
- Robbins, 709 P.2d 771 (Utah 1985) (no constitutional right to a bench trial; right to judge trial founded in rule 17(c))
- State v. Studham, 655 P.2d 669 (Utah 1982) (right to jury trial exists; waiver is controlled by procedural rule)
- State v. Davis, 689 P.2d 5 (Utah 1984) (procedural limitations on waiver of jury trial)
- State v. Bosh, 2011 UT 60 (Utah 2011) (interpretation of procedure rules reviewed for correctness)
- State v. Daniels, 2002 UT 2 (Utah 2002) (appellate review standard; questions of law clarified)
- United States v. United States District Court for Eastern District of California, 464 F.3d 1065 (9th Cir. 2006) (district court must consider safeguards to ensure fair jury trial before denying waiver)