Justia Utah Supreme Court Opinion Summaries

A real estate developer and his company sought to develop a large project in Fillmore, Utah, but encountered significant obstacles, including difficulties in securing land, water, and city approvals. The developer promoted the project publicly and requested city support, which drew media attention. A local newspaper and its reporter investigated the developer’s history and published a series of articles portraying him in a negative light, referencing past lawsuits, bankruptcies, and failed ventures. After the city rejected the project, the developer sued the newspaper and reporter for defamation, alleging that the articles contained false statements that caused lenders to withdraw support, resulting in substantial financial losses.The case was heard in Utah’s Fourth District Court. The defendants responded to the complaints and filed a special motion for expedited relief under Utah’s Uniform Public Expression Protection Act (UPEPA), arguing that the challenged statements were true, opinion, or otherwise protected. The district court granted the special motion, dismissing the defamation claims after a detailed review of each statement and finding them either true, vague, opinion, or privileged. The court admonished the plaintiff for certain litigation tactics and subsequently, upon the defendants’ request, awarded them nearly $400,000 in attorney fees and costs, accepting their submission without a task-by-task analysis of whether each fee was “related to” the special motion.On direct appeal, the Supreme Court of the State of Utah reviewed the fee award. The court held that a prevailing defendant in a UPEPA special motion must demonstrate that each fee was reasonably necessary to prosecute the special motion, not simply related to the case as a whole. Fees not meeting this standard are not awardable. The Supreme Court reversed the district court’s fee award, excluded certain fees, and remanded for further proceedings to determine relatedness and reasonableness consistent with its opinion. View "Aston v. Chronicle-Progress" on Justia Law

After an argument at an apartment, Deon Andre Jennings was charged with the murder of Willie Houston. During the confrontation, Houston asked Jennings to leave several times, but Jennings refused. When Houston stepped outside, Jennings attempted to lock him out, but Houston forced his way back in, ending up on top of Jennings. While on the floor, Jennings struck Houston in the back multiple times with an object. Houston left the apartment, sought help, and later died from deep stab wounds. Jennings claimed self-defense, asserting he struck Houston only to get him off, not to kill him, and that he did not know what object he used.The Third District Court, Salt Lake County, conducted a pretrial justification hearing under Utah Code section 76-2-309, which allows for an evidentiary hearing on self-defense before trial. Jennings argued that a written proffer of facts was sufficient to make a prima facie claim of justification, while the State contended evidence was necessary. The district court found that a proffer alone was not enough; it considered both Jennings’ proffer and his attached exhibits. The court determined that Jennings’ evidence did not support a claim that he reasonably believed force was necessary to defend himself, and found that Houston had not threatened or physically assaulted Jennings.The Supreme Court of the State of Utah affirmed the district court’s ruling. It held that, to make a prima facie claim of justification under the statute, a defendant must present evidence at the hearing that, if believed, would be legally sufficient to satisfy each element of a justification defense. This is a burden of production, not of proof. Because Jennings failed to present evidence indicating he subjectively believed the force he used was necessary for self-defense, the denial of his motion to dismiss was affirmed. View "State v. Jennings" on Justia Law

Two former seasonal employees of a ski resort were injured in a snowmobile accident after being laid off from their jobs. The accident occurred when, two days after their termination, they returned to the resort to drop off uniforms and accepted a ride from a current employee on a company snowmobile to attend a gathering organized by other former employees. The snowmobile crashed, causing serious injuries. Prior to their employment, both injured parties had signed a release agreement that waived the resort’s liability for injuries sustained from activities on resort property, including those caused by the resort’s negligence. The agreement specified that a free ski pass was consideration for the waiver.Both individuals brought lawsuits against the resort alleging vicarious liability for the employee’s negligence and direct liability for its own negligence. The Third District Court, Summit County, granted summary judgment in favor of the resort on the vicarious liability claims, finding no evidence the employee was acting within the scope of employment during the snowmobile ride. However, the district court denied summary judgment on the direct liability claims, relying on Pugmire v. Oregon Short Line Railroad Co., a 1907 Utah Supreme Court decision holding that employer-employee agreements waiving liability for employer negligence are void as contrary to public policy.On interlocutory appeal, the Supreme Court of the State of Utah affirmed the dismissal of the vicarious liability claims, concluding that there was no factual basis for a jury to find the employee acted within the course and scope of his employment. The court reversed the district court’s ruling on direct liability, holding that Pugmire applies only to releases for work-related injuries and does not bar enforcement of the waiver in this case, where the injuries occurred outside the employment context. The case was remanded for consideration of any other arguments regarding the release agreement. View "Deer Valley v. Olson" on Justia Law

Michael Johnson was charged with murder in connection with a death where the cause was disputed and involved conflicting evidence regarding physical injuries and substance use. At trial, Johnson’s counsel requested that the jury receive an instruction on the lesser-included offense of homicide by assault. However, the instruction given, which was drafted and approved by Johnson’s counsel, mischaracterized the required mens rea for homicide by assault. The jury convicted Johnson of intentional murder.On appeal, Johnson did not argue that his counsel was ineffective for proposing the erroneous instruction, nor did he claim the trial court committed plain error. Despite this, the Utah Court of Appeals raised the instructional error sua sponte and, applying the exceptional circumstances exception, found the error prejudicial and reversed the conviction. The Supreme Court of the State of Utah granted certiorari and reversed the Court of Appeals, holding that it was improper to address the instructional error under the exceptional circumstances exception since it had not been preserved or raised by the parties. The case was remanded, and the Court of Appeals summarily affirmed Johnson’s conviction.Johnson then sought postconviction relief, arguing his trial and appellate counsel were ineffective for failing to challenge the jury instruction. The Third District Court found deficient performance but concluded Johnson suffered no prejudice because the instruction’s first element required the jury to rule out murder before considering the lesser offense. Since the jury convicted on murder, the court found no reasonable probability of a different outcome.The Supreme Court of the State of Utah affirmed, holding that its prior decision vacated the Court of Appeals’ prejudice analysis, leaving the district court free to make its own ruling. It further held that Johnson could not establish prejudice, as the unchallenged first part of the instruction precluded conviction on the lesser offense once the jury found murder. View "Johnson v. State" on Justia Law

A defendant was charged with murder following an altercation at an apartment, where the victim died from stab wounds to his back. The defendant claimed he acted in self-defense, stating that the victim had ordered him to leave, attempted to re-enter forcefully, and ended up on top of him during a struggle. The defendant then struck the victim multiple times with an unknown object. There was no evidence or claim that the victim was armed or had threatened to use a weapon, and the victim subsequently sought help from a neighbor before succumbing to his injuries.The Third District Court in Salt Lake County held a pretrial justification hearing pursuant to Utah Code section 76-2-309. The defendant argued that he could make a prima facie claim of justification merely by proffering facts, which should be accepted as true. However, the district court interpreted the statute to require more than a proffer and considered both the defendant’s proffer and attached exhibits. The court found that the evidence did not support the defendant’s assertion of self-defense, as there was no indication he reasonably believed force was necessary to defend against imminent unlawful force or a forcible felony. Thus, the court denied the motion to dismiss.The Supreme Court of the State of Utah reviewed the interlocutory appeal. It held that to make a prima facie claim of justification under the statute, a defendant must present evidence at the hearing that, if believed by the factfinder, would be legally sufficient to satisfy each element of the justification claim. This is a burden of production, not of proof. The court concluded that the defendant had not presented evidence supporting each element of self-defense and affirmed the district court’s denial of the motion to dismiss. View "State v. Jennings" on Justia Law

An employee suffered a severe workplace injury in 2013 while working for a construction company, resulting in permanent and total disability with ongoing medical needs. The employee brought a third-party tort action against entities other than his employer involved in the accident and settled for $5 million. From the settlement, over $2.1 million was used to pay attorney fees and litigation expenses, with the remainder placed in trust. By the time of settlement, the employer and its workers’ compensation carrier had already paid over $1.5 million in benefits but stopped payments after the settlement, leaving the employee responsible for his ongoing care. The value of anticipated future medical costs was estimated at over $7 million.The administrative law judge (ALJ) initially found that only past benefits paid by the employer should be included in calculating the employer’s proportionate share of the legal expenses associated with the third-party settlement, setting that share at 31.6%. On review, the Commissioner disagreed, concluding that future anticipated benefits should also be included, as the employer’s interest in the recovery included the right to offset future benefits. The ALJ recalculated, finding the employer’s proportional share exceeded the total legal expenses, and ordered reimbursement to the employee for expenses already paid. The Appeals Board of the Labor Commission affirmed this decision.The Supreme Court of the State of Utah reviewed these decisions. It held that when an employer or insurance carrier seeks both reimbursement for past payments and an offset against future workers’ compensation liability from a third-party recovery, both past-paid and future-anticipated benefits must be considered in calculating the employer’s proportionate share of the legal expenses associated with that recovery. The court also held that the employer must reimburse the employee for its share of legal expenses before offsetting future benefits. Accordingly, the Supreme Court affirmed the decisions of the Labor Commission. View "Auto Owners Insurance v. Labor Commission" on Justia Law

A child was removed from the care of their mother in Utah after the mother experienced a mental health crisis, leading to the Utah Division of Child and Family Services (DCFS) taking protective custody of the child. The father, living in Georgia, sought custody. The juvenile court ordered DCFS to request a home study from Georgia officials via the Interstate Compact on the Placement of Children (ICPC). Georgia attempted to conduct the home visit twice, but was unable to complete it because the father lacked a stable residence. The court found the child could not safely be returned to the father and ultimately terminated his parental rights.The Second District Juvenile Court in Weber County initially adjudicated the child dependent as to the mother and neglected as to the father due to abandonment, later revising the finding to dependency after the father argued he had been denied access by the mother. Despite the father's efforts to establish paternity and seek visitation, the court maintained the child in DCFS custody with a goal of reunification. After two failed ICPC home studies due to the father's unstable housing, the court changed the permanency goal to adoption and terminated reunification services. DCFS then filed to terminate the father’s parental rights, and after trial, the juvenile court issued an order terminating those rights.The Supreme Court of the State of Utah reviewed the case on certification from the Utah Court of Appeals. The father argued that his appointed counsel was ineffective for not objecting to the use of the ICPC process or proposing alternatives for the required home visit. The Supreme Court held that counsel’s performance was not objectively unreasonable under the Strickland standard, noting that the ICPC was commonly used in these circumstances and alternatives were impractical or unlikely to be accepted. The court affirmed the termination of the father’s parental rights. View "In re B.G." on Justia Law

A religious organization planned to build a large temple in Heber Valley, Utah, and Wasatch County approved the project through a legislative development agreement. Several nearby property owners, concerned about adverse impacts on their health, welfare, privacy, and enjoyment of their property, filed a lawsuit against Wasatch County. They alleged that the county’s approval violated local land-use regulations and state law. The plaintiffs sought a declaration invalidating the ordinance and requested injunctive relief to halt construction.The Church of Jesus Christ of Latter-day Saints intervened, and both the Church and Wasatch County moved for summary judgment. The Fourth District Court granted summary judgment fully to the Church and partially to the County, finding that the ordinance was neither preempted nor contrary to law, and that plaintiffs had not overcome the highly deferential standard of review for land use actions. The court dismissed the case, prompting an appeal from the plaintiffs. After the Church began construction, the plaintiffs moved for an injunction to stop construction during the appeal. The district court granted the injunction, reasoning that plaintiffs would suffer irreparable harm if construction proceeded and was later found unlawful.The Supreme Court of Utah reviewed the district court’s order, focusing solely on whether the injunction should remain pending appeal. Applying Utah Rule of Appellate Procedure 8, the Court found that the plaintiffs had not identified specific irreparable harm that would result from construction during the appeal. The Court concluded that inconvenience or temporary changes to the land did not constitute irreparable harm absent clear evidence of injury that could not be remedied. Therefore, the Supreme Court of Utah granted the Church’s motion and suspended the injunction pending resolution of the appeal. View "VAN DUSEN v. WASATCH COUNTY" on Justia Law

The case concerns a criminal defendant charged with murder after an altercation in which the victim, following an argument at his own apartment, was stabbed twice in the back and later died. The defendant claimed self-defense, asserting that he acted to protect himself during a struggle after the victim re-entered the apartment and ended up on top of him. The defendant moved for a pretrial justification hearing under a Utah statute that allows the district court to determine, before trial, whether a defendant’s use of force was justified.The Third District Court held an evidentiary hearing on the defendant’s motion. At that hearing, the defendant provided both a written proffer of facts and attached exhibits, including a preliminary hearing transcript, but did not testify. The district court determined that a mere proffer of facts was insufficient and that the statutory burden required the defendant to present evidence supporting each element of the justification claim. After considering both the proffer and the exhibits, the court found that the defendant’s evidence did not show he subjectively believed the force he used was necessary to defend himself, and thus the court denied the motion to dismiss.On interlocutory appeal, the Supreme Court of the State of Utah addressed the procedural requirements of the pretrial justification statute. The court held that a defendant seeking a pretrial determination of justification must present evidence—rather than mere factual proffers—that, if believed, would be legally sufficient to satisfy each element of the justification defense. The court clarified that this is a burden of production, not a burden of proof. Applying this standard, the court concluded that the defendant failed to produce evidence supporting each element of self-defense and affirmed the district court’s denial of the motion to dismiss. View "State v. Jennings" on Justia Law

A man was charged with solicitation, conspiracy, and attempted murder after allegedly directing three women, with whom he had a polygamous relationship, to kill a fourteen-year-old girl, C.G., and her parents. The motive for the murder plot was to prevent C.G. from testifying in a pending rape case against him. The alleged plan involved the women breaking into the family’s home, but it was foiled when they were discovered, leading to their arrest. The prosecution sought to introduce evidence at trial regarding the rape case involving C.G., the defendant’s prior conviction for raping one of the co-conspirators, and the nature of his relationship with all three women, including his manipulative and coercive behavior.The Third District Court for West Jordan considered the defendant’s motion in limine to exclude this evidence. The court ruled that evidence about the rape case involving C.G. was intrinsic to the current charges, so not subject to Utah Rule of Evidence 404(b), but excluded most details about that case as irrelevant or unduly prejudicial under rules 401, 402, and 403. The court also excluded evidence of the prior rape conviction, finding it irrelevant and inadmissible under 404(b) and 403, and further excluded detailed evidence of manipulation and control over the women as unfairly prejudicial.The Supreme Court of the State of Utah granted the State’s petition for interlocutory review. The court affirmed the exclusion of the prior rape conviction under rule 403, finding its prejudicial effect outweighed its probative value. However, it held that the district court exceeded its discretion in excluding evidence about the rape case involving C.G. and the defendant’s manipulation of the women. The court adopted the rule that acts intrinsic to the charged crime are not “other acts” under 404(b), and found the probative value of this evidence was not substantially outweighed by unfair prejudice. The Supreme Court reversed the exclusions (except for the conviction) and remanded for further proceedings. View "State v. Blackwing" on Justia Law