State v. Van Huizen, 435 P.3d 202

At 16, Cooper Van Huizen participated in an armed robbery and was charged in juvenile court under the Serious Youth Offender Act; the juvenile court found probable cause and bound him over to district court.
In district court Van Huizen pleaded guilty to lesser robbery counts and received concurrent 1–15 year prison sentences.
While incarcerated, Van Huizen learned the juvenile judge who conducted the preliminary/bindover hearing was married to the Chief Criminal Deputy of the Weber County Attorney’s Office (the office that prosecuted him).
Van Huizen moved to reinstate time to appeal the bindover; the district court allowed appeal and the court of appeals vacated the bindover, finding an appearance of partiality and excusing preservation because the marital relationship was undisclosed.
The Utah Supreme Court granted certiorari on two questions: whether preservation rules applied to the undisclosed-bias claim, and whether prejudice must be shown when a judge fails to disclose a disqualifying relationship.
The Supreme Court reversed the court of appeals, holding preservation rules apply and Van Huizen failed to show an exception to preservation; it remanded the alternative claims to the court of appeals for consideration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether preservation applies to an undisclosed judicial-bias claim raised for the first time on appeal	Van Huizen: preservation excused because he lacked notice of the judge’s marital relationship and therefore could not have raised it below	State: claim was unpreserved and should be reviewed only under preservation exceptions (plain error, exceptional circumstances, ineffective assistance)	Preservation applies; party must raise claim below or show an exception; Van Huizen failed to meet that burden
Whether an undisclosed judge-spouse relationship requires vacatur without a showing of prejudice	Van Huizen: appearance of partiality alone is enough; prejudice need not be shown	State: even undisclosed relationships require preservation and, if preserved, prejudice or applicable standard must be shown	Court did not resolve whether prejudice is required because it decided preservation issue against Van Huizen; left prejudice question open
Whether plain error or exceptional-circumstances exceptions excuse lack of preservation here	Van Huizen: judge’s nondisclosure constituted a rare procedural anomaly excusing preservation	State: the record does not show inability to raise objection; plain error inapplicable because rule interpretation was not "plainly settled"	Neither plain error nor exceptional-circumstances applied; Van Huizen offered no affidavit from juvenile counsel and record did not show he was unable to object

State ex rel. D.B. v. State, 289 P.3d 459 (Utah 2012) (discussed in relation to notice-based preservation analysis)
State v. Johnson, 416 P.3d 443 (Utah 2017) (clarifies preservation exceptions: exceptional circumstances, plain error, ineffective assistance)
PC Riverview, LLC v. Xiao-Yan Cao, 424 P.3d 162 (Utah 2017) (appellate-review standard and affirmance on alternative grounds)
State v. Holgate, 10 P.3d 346 (Utah 2000) (plain error demonstration requirements)
In re Inquiry Concerning a Judge, 81 P.3d 758 (Utah 2003) (discusses when relationship to counsel does not require disqualification)
Helf v. Chevron U.S.A. Inc., 361 P.3d 63 (Utah 2015) (procedural rules on cross-appeals and appellate grounds)
Bailey v. Bayles, 52 P.3d 1158 (Utah 2002) (appellate courts may affirm on any legal ground apparent on the record)
State v. Dean, 95 P.3d 276 (Utah 2004) (cited on standards for plain error)