Ralphs v. District Court
Annotate this CaseIn 2009, Petitioner entered a plea in abeyance to a charge of lewdness that ultimately culminated in a conviction. In 2010, Petitioner was convicted of a second act of lewdness. In 2011 and 2012, Petitioner was subject to further lewdness charges. Petitioner was charged with felonies in light of his prior convictions. At this point, Petitioner sought to challenge his 2010 conviction, alleging that he had been deprived of his right to appeal the 2010 decision under the standards set forth in Utah R. App. P. 4(f) and Manning v. State. The justice court denied Petitioner’s motion. On de novo appeal to the district court, the court determined that Petitioner had waived the right to assert the denial of his right to appeal under Manning by waiting too long to assert that claim. Petitioner sought extraordinary relief challenging the dismissal of his appeal. The Supreme Court granted the petition, holding (1) Rule 4(f) governed Petitioner’s motion to reinstate his appeal from justice court to district court in a manner foreclosing the district court’s waiver analysis; (2) the district court retained jurisdiction to consider Petitioner’s motion; and (3) the Post-Conviction Remedies Act’s exclusive remedy provision was inapplicable.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.