Can Utah courts summon jurors from multiple counties for one trial? State v. Richins Explained

Background and Facts

In State v. Richins, the parties jointly appealed two district court decisions regarding jury selection in a high-profile aggravated murder case that garnered extreme media attention. The case involved consistent coverage by traditional media, YouTube channels with hundreds of thousands of subscribers, and courtroom overflow during hearings. The State and defendant first requested in-person jury selection rather than the Third District’s standard virtual process, and second sought to expand the jury venire to include prospective jurors from both Summit and Salt Lake counties.

Key Legal Issues

The Utah Supreme Court addressed two primary issues: whether the Presiding Judge abused her discretion in denying the request for in-person jury selection under the Third District’s standing order requiring “extraordinary circumstances,” and whether Utah’s Jury and Witness Act permits summoning prospective jurors from multiple counties for a single trial.

Court’s Analysis and Holding

The Court held that neither judge abused discretion. Regarding in-person jury selection, the Court found that the Presiding Judge reasonably concluded that media attention alone did not constitute extraordinary circumstances when virtual alternatives like tailored questionnaires and careful voir dire could address concerns. On the multi-county venire issue, the Court determined that Utah’s Jury and Witness Act requires jurors to be selected from a single county—specifically, “the county in which the trial will be held.” The Legislature’s repeated references to “a particular county” and specific statutory language demonstrated clear intent that jury pools consist of residents from one county only.

Practice Implications

This decision clarifies that parties cannot stipulate to waive statutory jury selection requirements, even in high-profile cases. The Court rejected arguments that the singular “county” could be read as plural or that parties could waive compliance with the Act. Practitioners should note that administrative decisions by presiding judges entered as orders in specific cases are reviewable on appeal, but the scope of what constitutes “extraordinary circumstances” for departing from standing orders remains narrow and fact-specific.