State v. Hon. Boyden, 441 P.3d 737

A man arrested using the name "Bela Fritz" pleaded guilty, was sentenced, and was delivered to the Utah State Prison under that identity.
At prison intake, staff suspected the person was not Bela Fritz and the defendant allegedly admitted using another person’s identity.
Within a month after judgment, the State moved under Utah R. Civ. P. 60(b) to vacate the conviction, sentence, and judgment on the ground of fraud/misrepresentation of identity and alternatively sought a misplea.
The district court denied the 60(b) motion, reasoning it lacked jurisdiction after imposition of sentence and that the Post-Conviction Remedies Act (PCRA) provided the State’s exclusive remedy.
The State petitioned the Utah Supreme Court for extraordinary relief under rule 65B to compel the district court to consider the 60(b) motion.
The Supreme Court concluded the district court abused its discretion, held Rule 60(b) was available to the State (PCRA did not bar it), and that the district court had jurisdiction to consider the motion; it vacated the denial and remanded for consideration of the 60(b) motion (but did not decide the merits).

Issue	State's Argument	Defendant/District Court's Argument	Held
Whether the State may move under Utah R. Civ. P. 60(b) to vacate a conviction obtained by a defendant’s misrepresentation of identity	Rule 60(b) applies where no other statute or rule governs; it permits relief for fraud and fills gaps in criminal procedure via rule 81(e)	60(b) is for losing parties; PCRA is the sole remedy for challenges to convictions/sentences	The State may invoke Rule 60(b) here; PCRA does not bar the State because PCRA applies to convicted persons, not the State
Whether the district court had jurisdiction postjudgment to hear the State’s 60(b) motion	Rule 60(b) supplies the court authority to act postjudgment; procedural "jurisdiction" under rules permits postjudgment relief	After imposition of a valid sentence, court loses subject-matter jurisdiction and cannot entertain such motions	Rule 60(b) confers jurisdictional authority for the district court to consider the motion despite ordinary postjudgment limitations
Whether the district court abused its discretion by refusing to address the State’s motion	Court should decide novel legal questions; failure to apply correct law is abuse of discretion	Declining to create new law is within court discretion	District court abused its discretion by refusing to adjudicate the State’s Rule 60(b) motion; Supreme Court vacated denial and directed the court to hear it

Kell v. State, 285 P.3d 1133 (Utah 2012) (Rule 60(b) cannot be read to include extra-textual limits like a pending-case requirement; PCRA can limit but not wholly extinguish Rule 60(b))
State v. Rodrigues, 218 P.3d 610 (Utah 2009) (general principle that a court loses subject-matter jurisdiction after imposition of a valid sentence)
State v. Barrett, 127 P.3d 682 (Utah 2005) (factors for extraordinary relief under rule 65B and standard for granting such petitions)
Menzies v. Galetka, 150 P.3d 480 (Utah 2006) (defendant previously obtained Rule 60(b)(6) relief in extraordinary circumstances; recognizes continued relevance of Rule 60(b))
In re Willey, 391 P.3d 171 (Utah 2016) (district courts have broad discretion on Rule 60(b) motions; review for abuse of discretion)