State v. Young
337 P.3d 227
Utah2014Background
- In December 2010, Young had sexual intercourse with A.S., a 13-year-old and his fiancée’s niece, and gave alcohol to A.S. and two other minors.
- In January 2011, the State filed a criminal information charging rape of a child and four counts of supplying alcohol to a minor; an amended information added five more counts of rape of a child.
- A scheduling conference was held and a preliminary hearing was requested, set for June 21, 2011.
- On the day of the scheduled preliminary hearing, Young pled guilty to one count of attempted aggravated sexual abuse of a child, and the remaining counts were dismissed.
- During the plea, the district court informed Young of various rights waivers under Rule 11, but the colloquy did not explicitly mention the right to a preliminary hearing.
- Young was sentenced on September 13, 2011 to a term of three years to life; he did not challenge the plea before sentencing and later sought appellate relief suggesting lack of jurisdiction due to no preliminary hearing or waiver.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court lacked subject matter jurisdiction to accept the guilty plea without a preliminary hearing or waiver. | State argues jurisdiction arose upon filing the information. | Young contends lack of preliminary hearing/waiver violated jurisdiction. | Jurisdiction existed; plea valid despite missing preliminary hearing/waiver. |
| Whether the absence of a boundover order or preliminary hearing is a nonjurisdictional defect that can be cured by pleading guilty. | State relies on Smith to show nonjurisdictional defect. | Young argues defect undermines valid jurisdiction. | Nonjurisdictional defect; plea admits elements and waives nonjurisdictional issues. |
Key Cases Cited
- State v. Smith, 2014 UT 33 (Utah 2014) (district court jurisdiction not contingent on bindover order; information filing grants jurisdiction)
- State v. Ott, 2010 UT 1 (Utah 2010) (withdrawal timing limits review of plea validity)
- Rhinehart, 2007 UT 61 (Utah 2007) (rights waivers and preliminary examination considerations)
- Schreuder, 712 P.2d 264 (Utah 1985) (magistrates and district court jurisdiction mechanics; historic context)