Sandoval v. State

Summary

The Utah Supreme Court affirmed summary judgment against Brandon Lee Sandoval’s petition for post-conviction relief. Sandoval argued that the destruction of physical evidence deprived him of due process and prevented post-conviction DNA testing. The court held that his standalone due process claim was procedurally improper and that he had not established the asserted state constitutional right or shown that the evidence destruction violated it.

Holdings

1. The Post-Conviction Remedies Act offered Sandoval no relief because he abandoned the claims that could fall within Utah Code section 78B-9-104 and sought relief based on post-conviction destruction of evidence, which is not one of the statute's enumerated grounds.
2. A rule 65C petition must seek relief under a specific provision of the PCRA; it is not a proper procedural vehicle for a standalone due process claim that is not itself grounded in a statutory PCRA remedy.
3. The court did not decide whether the Utah Constitution creates a due process right to post-conviction DNA testing, evidence retention, notice of destruction, or related procedures. In the alternative, Sandoval failed to carry his burden to establish that such a right exists or that the evidence destruction violated it.

Questions Presented

1. Whether Sandoval's rule 65C petition properly presented a standalone state constitutional due process claim based on the destruction of evidence and the resulting inability to seek post-conviction DNA testing.
2. Whether the Post-Conviction Remedies Act provided a statutory basis for the relief Sandoval sought.
3. Whether Sandoval established that the Utah Constitution creates a due process right to post-conviction DNA testing, evidence retention, or notice of evidence destruction, and that the destruction of the evidence violated that right.

Disposition

affirmed