Utah Supreme Court Affirms Sentence in State v. Houston
SALT LAKE CITY (Feb 24, 2015) — In a 4-1 decision written by Justice Nehring with Justice Durham dissenting, the Utah Supreme Court affirmed the Life Without Parole (LWOP) sentence for Robert Cameron Houston in State v. Houston. The State originally charged Houston with the aggravated murder, aggravated sexual assault, and rape of Raechale Elton, a staff member of the residential treatment center for youth where Houston was temporarily residing. Houston pled guilty to aggravated murder and the State agreed to drop the other charges. He then appealed the sentence contending that he had ineffective assistance of counsel during the sentencing proceeding and his constitutional rights were violated. The Utah Supreme Court found that Houston’s sentencing was constitutional and that his counsel was not ineffective.
“I am extremely relieved that the victim’s family finally has a resolution in this case. The appellate process has been a long road and I am grateful that it has finally come to a favorable end,” said Assistant Attorney General Christopher Ballard, who drafted and argued the appeal to the Utah Supreme Court. “The Court correctly affirmed the jury’s conclusion that life without parole is the only appropriate sentence for this viciously selfish crime. This case did not involve just a single, inexplicable violent episode, but rather the culmination of a relentless history of escalating sexual violence.”
In February 2006, seventeen-and-a-half-year-old Robert Houston was housed at a home for troubled teens in Clearfield, Utah due to two prior sexual assaults at knife-point. While at the group home, he attempted to attack another female counselor and was caught planning another attack. He then coerced a female counselor, Raechale Elton, to give him a ride to one of the group homes where no other residents or staffers were present. He then attacked Elton with a knife, forced her to disrobe, and proceeded to rape her at knife-point even though she begged him not to. He then slit her throat, tried to rip out her trachea, and stabbed her to death because, according to him, she wouldn’t stop screaming.
“Our office’s Criminal Appeals Division has knowledgeable and skilled attorneys who continually strive for justice. For years, Assistant Attorney General Christopher Ballard has conscientiously dedicated his time and expertise in the AG’s Office to resolve this case for Raechale’s family,” said Attorney General Sean Reyes. “Thanks, in large part due to Christopher Ballard and our Criminal Appeals team, this decision not only affirms key legal points, but will also guide cases for years to come.”
In the decision, the Utah Supreme Court held that the Legislature is in the best position to determine the generally applicable range of appropriate sentences for particular crimes, subject only to broad constitutional constraints. The Court also held that the individual sentencer is in the best position to decide the specific punishment that is appropriate in light of all of the facts of the crime and the Defendant’s background. In addition, the Court recognized that when imposing sentence on a juvenile that is being held responsible as an adult, Utah law adequately allows the sentencer to consider the unique characteristics of youth.
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