Can Utah courts create exceptions to statutory time limits for post-conviction relief? Patterson v. State Explained

In Patterson v. State, the Utah Supreme Court addressed fundamental questions about the relationship between constitutional writ authority and statutory limitations on post-conviction relief. The case arose when Scott Patterson filed a petition for post-conviction relief more than three years after his certiorari petition was denied, well beyond the one-year deadline established by the Post-Conviction Remedies Act (PCRA).

Background and facts

Patterson was convicted of aggravated sexual abuse of a child and other offenses. After his conviction was affirmed on appeal and certiorari was denied, his appellate counsel advised him about his options for further review. Patterson filed a federal habeas petition in 2014 but did not file a state post-conviction petition until 2016, arguing that various circumstances should toll the PCRA’s time limitations or that an egregious injustice exception should apply.

Key legal issues

The court addressed several critical issues: whether the PCRA’s time limitations could be tolled based on alleged ineffective assistance of counsel or lack of access to courts; whether Utah courts possess constitutional writ authority independent of the PCRA; the scope of legislative power to regulate extraordinary writs; and whether an egregious injustice exception exists to override statutory time bars.

Court’s analysis and holding

The court affirmed the dismissal of Patterson’s petition on multiple grounds. It found no basis for tolling the statute of limitations, rejecting arguments about deficient counsel advice and inadequate prison legal resources. Significantly, the court clarified that Utah courts derive writ authority from article VIII of the Utah Constitution, not merely from the suspension clause. The court explained that this constitutional authority encompasses the power to issue writs for post-conviction challenges as understood when the 1984 constitutional amendment was adopted.

However, the court definitively rejected the concept of an egregious injustice exception to the PCRA’s procedural bars. The court explained that under current law, time-barred cases can only be heard when failure to do so would violate a petitioner’s constitutional rights, and Patterson failed to make such a showing under either the Open Courts Clause or Suspension Clause.

Practice implications

This decision provides crucial guidance for practitioners handling post-conviction matters. The court’s rejection of an egregious injustice exception eliminates a previously uncertain avenue for challenging time-barred petitions. Practitioners must carefully monitor PCRA deadlines and cannot rely on equitable exceptions absent a clear constitutional violation. The decision also clarifies the constitutional framework governing extraordinary writs, though questions remain about the distinction between substantive and procedural limitations on writ authority.