Hurst v. Cook
In Hurst v. Cook, 777 P.2d 1029, 1036-37 (Utah 1989), the Court articulated five factors that constitute sufficient "good cause" to allow the filing of successive post-conviction petitions. Id. at 1037.
Those factors are:
(1) the denial of a constitutional right pursuant to new law that is, or might be, retroactive;
(2) new facts not previously known which would show the denial of a constitutional right or might change the outcome of the trial;
(3) the existence of fundamental unfairness in a conviction;
(4) the illegality of a sentence; or;
(5) a claim overlooked in good faith with no intent to delay or abuse the writ. Id.