SCM NEWS & OPINIONS

State v. Van Huizen, 2019 UT 01 (Jan. 7, 2019)

After pleading guilty to armed robbery, a juvenile defendant challenged his bindover based on a claim of judicial bias discovered after sentencing.  The court of appeals vacated the conviction.  Reversing, the supreme court held the court of appeals erred in exempting the defendant’s judicial bias claim from the preservation rule.  The court emphasized that rules governing preservation apply to all cases, even those presenting issues of judicial bias.