The Utah Supreme Court issued a unanimous opinion in *State v. Najera* addressing the constitutional limits of police questioning sexual assault victims in hospital settings, a decision that could establish new precedent for law enforcement protocols in sensitive cases.
The case, filed November 28, 2025, stems from an incident in the early morning hours when a woman walked into an emergency room and reported she had been raped. While the victim was waiting to be seen in an exam room, a police officer arrived to "get the basic information" to assess the situation and report back to his supervisor.
According to the court's opinion authored by Justice Hagen, the officer's encounter with the victim lasted approximately 20 minutes. During this time, the officer asked only three substantive questions about the incident: where it happened, whether she knew who committed the assault, and if she had a description of the perpetrator.
The court's opinion provides detailed insight into the victim's condition during the questioning. As she attempted to answer the officer's questions, the woman volunteered additional details about the assault while appearing to think aloud as she struggled to recall and process what had happened to her. The opinion notes that as memories would surface, she would gasp, gag, dry heave, cry, hide her face, and tell herself this could not be happening to her.
Following the officer's departure, the woman was examined by a Sexual Assault Nurse Examiner (SANE). The court's opinion explains that SANEs are specially trained nurses who provide medical care to victims while simultaneously documenting injuries and collecting evidence for law enforcement. This dual approach helps avoid subjecting sexual assault victims to multiple examinations.
The case reached the Utah Supreme Court on appeal of an interlocutory order from the Third District Court in Salt Lake County, where the Honorable Vernice S. Trease presided over the original proceedings. The appeal was heard February 28, 2025, before being decided in November.
The state was represented by Attorney General Derek E. Brown and Assistant Solicitor General Daniel W. Boyer. Appellant Arthur Wayne Najera was represented by Sarah J. Carlquist of Salt Lake City.
All five justices joined in the unanimous decision written by Justice Hagen. The court included Chief Justice Durrant, Associate Chief Justice Pearce, Justice Petersen, and Justice Pohlman.
While the complete text of the opinion was not available, the case appears to address fundamental questions about when and how police officers may question sexual assault victims who are seeking medical treatment. The timing and setting of such interviews raise constitutional questions about the voluntariness of statements and the balance between law enforcement needs and victim welfare.
The hospital emergency room setting presents unique challenges for law enforcement. Victims may be in shock, experiencing trauma, or under medical care that could affect their ability to provide voluntary statements. The court's examination of this 20-minute encounter suggests careful consideration of these factors in determining appropriate boundaries for police questioning.
The case comes at a time when law enforcement agencies across the country are reevaluating their protocols for handling sexual assault cases. Many jurisdictions have implemented trauma-informed approaches that prioritize victim welfare while still gathering necessary evidence for prosecution.
The Utah Supreme Court's decision in *Najera* may provide guidance for other courts and law enforcement agencies grappling with similar issues. The unanimous nature of the decision suggests the court reached clear conclusions about the constitutional boundaries in these sensitive situations.
Sexual assault cases present particular challenges for the criminal justice system, requiring careful balance between victim rights, due process considerations, and effective law enforcement. The hospital setting adds additional complexity, as victims are often seeking immediate medical care while law enforcement seeks to gather time-sensitive evidence and information.
The court's detailed description of the victim's physical and emotional responses during questioning highlights the vulnerable state of sexual assault victims and the need for careful consideration of their condition when determining the admissibility of statements made to police.
This decision may influence how police departments train officers responding to sexual assault cases, particularly regarding the timing, location, and manner of initial victim interviews. The ruling could also affect how prosecutors handle evidence gathered from hospital-based police encounters with sexual assault victims.
The case record indicates this was an interlocutory appeal, meaning it addressed a specific legal issue before the underlying criminal case was fully resolved. Such appeals are typically granted only when the issue is of particular legal significance or when waiting for final resolution would cause substantial harm.
The *Najera* decision adds to Utah's body of law regarding police questioning and sexual assault cases, providing guidance for lower courts, law enforcement, and legal practitioners handling similar cases throughout the state.