In 1890, the The Church of Jesus Christ of Latter-day Saints renounced polygamy, which gave Utah permission from the federal government to being drafting a constitution.
A mere five years later the court retreated from this position and in American Fork City v. Crosgrove, 701 P.2d 1069 (Utah 1985), overruled Hansen.
It is now clear that Article I, § 14 of the Utah Constitution provides greater protection to the privacy of the home and automobiles than does the Fourth Amendment.
[5] The expansion of the protection afforded by the state constitution has not been based upon distinctions in the language used, nor has it been the result of Utah's unique political and religious history.
[7] In Brigham City v. Stuart, 2005 UT 13, ¶10, 122 P. 3d 506, 510, the Utah Supreme Court expressed "surpris[e]" in "[t]he reluctance of litigants to take up and develop a state constitutional analysis," ibid., the court expressly invited future litigants to bring challenges under the Utah Constitution to enable it to fulfill its "responsibility as guardians of the individual liberty of our citizens" and "undertak[e] a principled exploration of the interplay between federal and state protections of individual rights," id., at 511.