Can procedural bars prevent post-conviction relief claims? Lynch v. State Explained

The Utah Court of Appeals in Lynch v. State provides important guidance on procedural barriers that can prevent post-conviction relief and the demanding standard for newly discovered evidence claims under Utah’s Post-Conviction Remedies Act (PCRA).

Background and Facts

Sherman Lynch was convicted of murdering his wife in a hit-and-run collision involving a white truck he owned. After his conviction was affirmed on direct appeal, Lynch filed a PCRA petition raising 29 issues, primarily claiming ineffective assistance of counsel and newly discovered evidence. The State moved for summary judgment, arguing many claims were procedurally barred because Lynch had raised them in his new trial motion.

Key Legal Issues

The case addressed two critical PCRA issues: (1) whether claims raised in new trial proceedings are procedurally barred under Utah Code section 78B-9-106(1)(b), which bars claims “raised or addressed at trial or on appeal,” and (2) the standard for newly discovered evidence under section 78B-9-104(1)(e), which requires showing “no reasonable trier of fact could have found the petitioner guilty.”

Court’s Analysis and Holding

The court clarified that “trial” proceedings under the PCRA encompass “everything that happens in the trial court,” including new trial motions. Therefore, Lynch’s claims about his truck’s examination, paint evidence, and witness Ashe were procedurally barred because he had raised them in his new trial motion. For his remaining claims, the court applied the ineffective assistance of appellate counsel framework, finding Lynch could not show his appellate counsel overlooked obvious issues that would have resulted in reversal. Regarding newly discovered evidence from two investigators claiming police planted zip ties, the court found their testimony contradictory and insufficient to meet the demanding PCRA standard.

Practice Implications

This decision underscores the importance of strategic case planning in post-conviction proceedings. Practitioners must carefully analyze whether claims were previously raised in any trial court proceeding, not just the trial itself. The case also demonstrates the extremely high bar for newly discovered evidence claims, requiring proof that no reasonable jury could convict given the new evidence—a much more demanding standard than the pre-PCRA requirement of merely making a different result probable on retrial.