What constitutes newly discovered material evidence in Utah PCRA petitions? Logue v. State Explained

In Logue v. State, the Utah Court of Appeals addressed the challenging standard for proving newly discovered material evidence under Utah’s Post-Conviction Remedies Act (PCRA). This case demonstrates how even dramatic witness recantations may fail to meet the statutory requirements when other evidence strongly supports the conviction.

Background and Facts

Danny Logue was convicted of aggravated murder based largely on witness testimony, as physical evidence was limited. Key witness Brandon Wright testified that Logue admitted to shooting the victim. Years later, Wright sent letters recanting his trial testimony, stating that Logue never admitted to killing the victim and that Wright had lied about reading case documents before testifying. Logue filed a PCRA petition claiming Wright’s recantation constituted newly discovered material evidence requiring vacation of his conviction.

Key Legal Issues

The court addressed whether Wright’s recantation met the four-part test for newly discovered material evidence under Utah Code Ann. § 78B-9-104(1)(e), particularly the requirement that the evidence demonstrate “no reasonable trier of fact could have found the petitioner guilty.” The court also considered whether Logue’s ineffective assistance of appellate counsel claim was properly preserved.

Court’s Analysis and Holding

The Court of Appeals affirmed summary judgment for the State. Despite Wright’s recantation, substantial other evidence supported Logue’s conviction, including testimony from his girlfriend and his co-defendant’s girlfriend, cell phone records, and Logue’s own admissions. Significantly, the court noted that in Logue’s direct appeal, sufficient evidence was found to support his conviction “without any reference whatsoever to Wright’s trial testimony.” The court concluded Wright’s recantation failed the statutory test because a reasonable trier of fact could still have found Logue guilty based on the remaining evidence.

Practice Implications

This decision reinforces the extremely high bar for newly discovered material evidence claims under the PCRA. Even complete witness recantations may be insufficient if other evidence strongly supports the conviction. Practitioners should carefully evaluate whether recanted testimony would truly prevent any reasonable jury from finding guilt, rather than merely undermining one piece of evidence among many. The case also emphasizes proper pleading requirements—claims must be raised in the initial PCRA petition, not first introduced in summary judgment opposition.