When does eligibility for extraordinary relief become entitlement under Utah Rule 19? Adams v. Salt Lake City Explained

Background and facts

George Adams allegedly caused a multi-vehicle crash while intoxicated. Salt Lake City charged him in the Salt Lake City Justice Court with DUI (class B misdemeanor) and related offenses. When Adams attempted to plead guilty, the City withheld prosecutorial consent as required by Utah Code section 41-6a-513—the prosecutorial consent law—which renders any guilty or no-contest plea to a DUI charge invalid without the prosecutor’s agreement. The justice court denied Adams’ motion to declare the law unconstitutional, dismissed the case without prejudice at the City’s request, and the Salt Lake County District Attorney simultaneously refiled enhanced charges in district court, elevating the DUI to a third-degree felony. Because Adams was never convicted or sentenced, he had no right to a direct appeal.

Key legal issues

Adams petitioned the Utah Supreme Court for extraordinary relief under Utah Rule of Appellate Procedure 19 and Utah Rule of Civil Procedure 65B, raising two constitutional challenges: (1) that the prosecutorial consent law violates Utah’s separation of powers clause by allowing the executive branch to encroach on judicial authority over guilty pleas, and (2) that the law violated his due process rights under the Utah and United States Constitutions.

Court’s analysis and holding

The Court articulated a three-hurdle framework for rule 19 petitions: (1) no other plain, speedy, or adequate remedy exists; (2) grounds for relief are established under rule 65B; and (3) the petitioner persuades the court to exercise its discretion to grant the extraordinary relief sought. The Court confirmed that clearing all three hurdles is required, but they may be addressed in any order.

On the separation of powers challenge, the Court agreed Adams properly invoked rule 19—he had no other avenue to obtain the specific remedy he sought (return to justice court to plead guilty). However, the Court declined to reach the constitutional merits, exercising its discretion to deny the petition because Adams failed to show that vacating the justice court’s decision would produce meaningful relief. Enhanced felony charges remained pending in district court, the justice court retained discretion under Utah Rule of Criminal Procedure 11(e) to refuse any guilty plea, and Adams himself conceded at oral argument a “substantial possibility” the justice court would deny his plea. Invoking the doctrine of constitutional avoidance, the Court declined to resolve a constitutional question unlikely to benefit the petitioner.

On the due process challenge, the Court rejected Adams’ petition because he argued the legal merits before the Supreme Court without addressing the justice court’s actual ruling—that the due process argument was inadequately briefed. Failing to challenge the rationale for the lower court’s decision means a petitioner cannot demonstrate an abuse of discretion under rule 65B, the required ground for relief.

Practice implications

Utah appellate practitioners must understand that eligibility for extraordinary relief is not entitlement. Even a petitioner who clears the first two rule 19 hurdles must independently persuade the court that circumstances warrant discretionary intervention. Petitions should include a targeted showing of concrete, non-speculative benefit flowing from the requested relief. Equally important: when challenging a lower court ruling as inadequately addressing your argument, you must first attack the lower court’s actual stated rationale—not merely re-argue the underlying merits—or the petition will fail at the second hurdle.