State v. Menzies, 2025 UT 38

Posted by Stone River Criminal Defense Team

Last Updated: September 11, 2025

August 30, 2025 - The Utah Supreme Court has halted the execution of death row inmate Ralph Leroy Menzies, ruling that the district court erred when it denied his petition for a new competency hearing despite evidence of worsening dementia.
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Utah Supreme Court Halts Execution of Ralph Menzies Over Dementia Concerns

The high court’s unanimous decision in State v. Menzies, 2025 UT 38, emphasizes that individuals facing execution must have a rational understanding of why the state is executing them. Based on new medical evaluations, the court found that Menzies may no longer meet that constitutional standard.

Conviction and Diagnosis

Menzies was convicted of the 1986 murder of Maurine Hunsaker and sentenced to death in 1988. Decades of appeals followed. In early 2024, the State of Utah sought an execution warrant. But by that time, Menzies had been diagnosed with vascular dementia. This progressive, degenerative brain disorder can cause severe memory loss, cognitive impairment, and confusion.

After an initial competency hearing, the district court acknowledged Menzies’s dementia diagnosis but found him competent to be executed. Menzies appealed that ruling and also sought to halt his execution while the appeal was pending. The court denied his stay request.

New Medical Reports Prompt a Second Petition

A month later, Menzies submitted new evidence. Two neurologists had re-evaluated him and found that his condition had worsened. They said Menzies no longer understood why he was being executed. A corrections officer who worked with Menzies confirmed signs of serious decline.

Despite this, the trial court denied his request for a second competency hearing. It also issued a warrant to execute him on September 5, 2025. Menzies appealed again and asked the Utah Supreme Court to intervene.

The Supreme Court Steps In

The Utah Supreme Court ruled that the district court used the wrong legal standard. Under state law, a successive petition for a competency hearing needs only show:

  1. A substantial change in circumstances since the last ruling, and
  2. Raises a serious question about their ability to understand the reason for their execution.

The court emphasized that judges at this stage must only determine whether the petition itself meets these two requirements—not weigh competing evidence. The Supreme Court found that Menzies’s new petition, which included recent evaluations indicating that he no longer understands why he is being executed, clearly met the legal threshold.

Execution Warrant Was Premature

The Supreme Court also said the trial court should not have issued an execution warrant while a legal challenge to Menzies’s competency was still pending. That appeal involved his fundamental constitutional rights. As a result, the justices vacated the execution warrant.

What Happens Now

The ruling sends the case back to the trial court for a new hearing on Menzies’s mental fitness.

Why It Matters

This decision reinforces that courts must take mental competency seriously—especially when a life is at stake. If an inmate may no longer understand why they’re being executed, the law requires courts to take a second look.

Originally Published: September 11, 2025

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