Arriaga v. StateAnnotate this Case
The Supreme Court affirmed the opinion of the court of appeals affirming the judgment of the post-conviction court denying Petitioner's pro se petition under the Post-Conviction Remedies Act, Utah Code 78B-9-101 to -503, holding that Petitioner failed to identify a material dispute sufficient to rebut the State's showing that he was not prejudiced by his guilty plea or the State's showing that his trial counsel's performance was not deficient.
Petitioner pled guilty to first-degree murder. In his post-conviction petition, Petitioner argued that his guilty plea was unknowing and involuntary because he did not understand that the absence of imperfect self-defense was an element of murder and that he received ineffective assistance of counsel because of a language barrier with trial counsel. The post-conviction court granted summary judgment in favor of the State, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) Petitioner's claim that his plea was unknowing and involuntary failed because there was no genuine issue of material fact as to whether he was prejudiced as a result; and (2) no genuine issue of material fact existed as to whether trial counsel's failure to obtain an interpreter constituted deficient performance.