Archuleta v. State
Archuleta v. State, 2020 UT 62 (Petersen, J.)
Post-Conviction Relief
The defendant was convicted and sentenced to death and filed a series of post-conviction relief (PCRA) petitions. In his last petition, he argued that under Atkins v. Virginia, 536 U.S.304 (2002), it was cruel and unusual punishment to execute him because he was intellectually disabled; he also raised several other claims. The district court dismissed all of the defendant’s claims on summary judgment. The Utah Supreme Court affirmed, holding:
- The defendant’s Atkins claim is not cognizable under the PCRA. The PCRA does allow a defendant to challenge a sentence that “was imposed” unconstitutionally. Utah Code § 78B-9-104(1)(a). But it was not unconstitutional to execute an intellectually disabled person until several years after the defendant was sentenced, so the sentence “was [not] imposed” unconstitutionally. Neither was the Atkins rule dictated by precedent existing at the time the defendant was sentenced, so section 78B-9-104(1)(f) does not apply.
- Although the PCRA does not contain a provision that recognizes an Atkins claim, the defendant may be able to assert his Atkins claim under Utah R. Crim. P. 22(e), which allows for a correction of an unconstitutional sentence.
- The defendant’s remaining PCRA claims are procedurally barred because he either already litigated them in prior PCRA petitions or could have raised the claims but did not do so in a prior petition.