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SALT LAKE CITY — A man who "spontaneously confessed" to a home invasion and assault of a 72-year-old widow while in police custody before his Miranda rights were explained to him had his conviction vacated by the Utah Court of Appeals.
The court's opinion, filed on Dec. 14, said William Allen Uptain was being interviewed while in jail on drug charges when officers brought up the home invasion case, which occurred close to where he lived.
After he confessed, he was given Miranda warnings and then confirmed his confession. After being convicted during a jury trial in September 2021, Uptain argued his attorney was ineffective because the attorney did not seek to suppress his confessions. He said prosecutors had no other evidence that he is guilty.
Uptain was sentenced in the case to five years to life in prison for aggravated burglary, a first-degree felony, and one to 15 years in prison for robbery, a second-degree felony.
The home invasion
In February 2021, an unidentified man broke into a widow's home in Green River, in Emery County. The woman heard her dog barking, and saw a man at her kitchen door with a ski mask and gloves on.
The opinion said the man ran toward the woman, "grabbed her by the hair, yanked her out of her chair, and grasped her by the neck, warning, 'Don't scream. All I want is money.'"
The man attempted to leave with her purse, but the woman grabbed his sweater to attempt to stop him when he punched her in the chest. She got up and attempted to follow him again, but could not determine which direction he went and called the police.
Officers did not find the suspect in their search and did not gather any forensic evidence or video evidence. Uptain was discussed as a suspect because he lived nearby.
The interview and trial
Uptain was arrested on unrelated warrants on March 4, and when a home invasion was brought up, he was asked if he knew about it. Police reported he said, "I regret it so much, man. I know I need help. … I was waiting for you to ask me about that," the opinion said.
After the Miranda rights recitation was completed, Uptain shared more details about the home invasion.
The Court of Appeals said although the detective did give the warnings after Uptain began confessing, "it was too late."
A recording of the interview was played at Uptown's trial. At the trial, Uptain's attorney said he was simply saying the things he thought would get him into drug treatment.
While the case was ongoing, Uptain, without an attorney, filed a motion to dismiss and asked for a "suppression hearing," instead of a hearing on a motion to suppress, but the court refused to consider the motions because Uptain had an attorney who had not backed the motions. Uptain also filed motions asking the court for a new attorney.
The appellate court determined that because the confession was the only evidence connecting Uptain to the home invasion, his attorney not filing a motion to suppress that evidence was prejudicial to his case.
"Had a motion to suppress Uptain's confession been filed, it would have been meritorious," the opinion said.
The case will now go back to the 7th District Court, where a motion to suppress the interview will likely be filed now that the conviction is vacated.
