Justia Utah Supreme Court Opinion Summaries

Stephen Rippey pled guilty to one count of aggravated sexual abuse of a child and one count of object rape of a child. He was sentenced to two concurrent prison terms of fifteen years to life. Ten years after his conviction, a district court reinstated Rippey’s time to file a direct appeal. On appeal, Rippey challenged several aspects of his plea, conviction, and sentence, leading the Supreme Court of Utah to address whether the Plea Withdrawal Statute (PWS) is constitutional.The Third District Court in West Jordan initially accepted Rippey’s guilty plea after a colloquy and a signed plea form. Rippey did not move to withdraw his plea before sentencing. He later filed a pro se petition for post-conviction relief under the Post-Conviction Remedies Act (PCRA), listing seventeen claims. The district court dismissed eight claims as frivolous and the remaining claims for failure to state a claim. Rippey’s requests for appointed counsel were denied. The Utah Court of Appeals upheld the district court’s dismissal, concluding that Rippey’s claims were unpreserved except for ineffective assistance of counsel, which lacked merit.The Supreme Court of Utah reviewed the constitutionality of the PWS, specifically subsections (2)(b) and (2)(c). The court held that subsection (2)(b)’s preservation rule and the corresponding waiver in subsection (2)(c) violate the separation of powers under the Utah Constitution. These provisions were deemed procedural, not substantive, and thus beyond the legislature’s authority to enact. The court concluded that the PWS does not bar Rippey’s challenge to his guilty plea, and his appeal is now governed by standard rules of preservation. The court instructed the parties to brief the merits of Rippey’s challenges under these standards. View "State v. Rippey" on Justia Law

The case involves William Torres, who was convicted by a jury of one count of rape. The district court had concerns about the performance of Torres's trial counsel and appointed post-trial counsel to investigate potential errors. Torres, through his new counsel, moved for a new trial, arguing ineffective assistance of counsel under the Strickland v. Washington standard, which requires showing that counsel's performance was deficient and that the deficient performance prejudiced the defense.The district court granted Torres a new trial, finding that his trial counsel's performance was objectively unreasonable in several respects and that these errors cumulatively prejudiced Torres. The court concluded that Torres received ineffective assistance of counsel and ordered a new trial under rule 24(a) of the Utah Rules of Criminal Procedure.The State appealed, and the Utah Court of Appeals reversed the district court's decision. The court of appeals reviewed the district court's determination of ineffective assistance of counsel for correctness, as per existing precedent. The court concluded that Torres had failed to show that his trial counsel's performance was both deficient and prejudicial under Strickland.On certiorari, Torres argued that the court of appeals applied the wrong standard of review and that the district court's ruling should be reviewed for abuse of discretion. The Utah Supreme Court rejected this argument, affirming that legal decisions embedded in a district court's new trial ruling are reviewed for correctness. The court also declined to overrule its precedent in Menzies v. Galetka, which holds that ineffective assistance is a law-like mixed question reviewed for correctness.The Utah Supreme Court agreed with the court of appeals that Torres had not established a reasonable probability of a different result at trial absent counsel's alleged errors. Consequently, the court affirmed the decision of the court of appeals, reversing the district court's grant of a new trial and remanding for sentencing. View "State v. Torres-Orellana" on Justia Law

Randi Mariani crashed her motor scooter and sustained a serious injury during a driving skills test, which she was taking to obtain a motorcycle endorsement to her driver license. Following the crash, the Utah Department of Public Safety-Driver License Division (DLD) denied Mariani’s application for the endorsement. Mariani sued the DLD for negligently causing her injury. The district court granted summary judgment to the DLD based on governmental immunity, and the court of appeals affirmed.The district court concluded that the DLD was immune from Mariani’s suit under the Governmental Immunity Act of Utah (GIA), reasoning that Mariani’s injury arose out of the administration of her motorcycle skills test, which was part of the licensing process. The court of appeals agreed, stating that Mariani’s injury was at least incident to the licensing approval process.The Utah Supreme Court reviewed the case to determine whether the court of appeals erred in affirming the district court’s decision. The Supreme Court focused on the specific language of the GIA’s licensing exception, which provides immunity for injuries that arise out of or in connection with the denial of a license. The Court concluded that the relevant conduct was the denial of the motorcycle endorsement, not the licensing process itself. The Court further determined that there was no causal relationship between the denial of the license and Mariani’s injury, as the injury occurred before the denial. Therefore, the licensing exception did not apply, and the DLD was not immune from Mariani’s suit. The Supreme Court reversed the court of appeals’ decision and remanded the case for further proceedings. View "Mariani v. Driver License Division" on Justia Law

A customer, Davie Montes, purchased a used car from National Buick GMC (National) and signed two agreements: a Purchase Agreement and an Arbitration Agreement. The Purchase Agreement included an integration clause stating it was the complete and exclusive statement of terms. The Arbitration Agreement, which did not have an integration clause, covered disputes related to the purchase or financing of the vehicle. After experiencing issues with the car, Montes sued National, which then moved to compel arbitration based on the Arbitration Agreement.The Fourth District Court in Provo denied National's motion, ruling that the Purchase Agreement's integration clause made it the sole agreement between the parties. The Utah Court of Appeals affirmed this decision, interpreting Utah precedent to mean that the integration clause precluded consideration of the Arbitration Agreement.The Supreme Court of the State of Utah reviewed the case and reversed the lower courts' decisions. The Supreme Court held that contemporaneous, executed agreements related to the same transaction should be construed together, even if one contains an integration clause. The court found that the Purchase Agreement and the Arbitration Agreement were part of the same transaction and should be considered together. The case was remanded for further proceedings consistent with this opinion. View "Montes v. National Buick GMC" on Justia Law

Erik Schnibbe, an attorney, worked at the law firm of Magleby, Cataxinos, and Greenwood. After a client of the firm won a large damages award, the firm paid Schnibbe $1 million for his share of the contingency fee via direct deposit. Schnibbe believed he was promised a greater share and kept the $1 million. Years later, after leaving the firm, he sued for the additional money he claimed he was owed.The Defendants, including the firm and two of its attorneys, moved for summary judgment, arguing that Schnibbe had accepted the $1 million as full settlement of his share of the contingency fee, thus barring his claims under the doctrine of accord and satisfaction. The district court agreed and granted summary judgment to the Defendants.The Utah Court of Appeals affirmed the district court's decision, concluding that all three elements of accord and satisfaction were met: an unliquidated claim or bona fide dispute over the amount due, a payment offered as full settlement of the entire dispute, and acceptance of the payment as full settlement of the dispute. The court focused on the acceptance element, determining that Schnibbe's retention of the $1 million for four years without attempting to return it or registering a protest constituted acceptance of the payment as full settlement.The Utah Supreme Court reviewed the case on certiorari. The court agreed with the lower courts that Schnibbe's conduct indicated acceptance of the payment as full settlement. The court clarified that acceptance could be inferred from the totality of the circumstances, including the creditor's retention of the funds, even if the payment was received passively via direct deposit. The court held that Schnibbe's knowing retention of the $1 million for several years, without attempting to return it, constituted acceptance of the proposed accord as a matter of law. The court affirmed the decision of the court of appeals. View "Magleby v. Schnibbe" on Justia Law

In 2015, Michael Jerry Felts pled guilty to assaulting a police officer and failing to stop at the command of police. The State sought restitution for damage to a police vehicle during the pursuit. The district court referred the restitution question to the Board of Pardons and Parole, which ordered Felts to pay $9,415.28 in June 2021. Felts objected, arguing that insurance had already covered the damage. After legislative amendments in July 2021 removed the Board's authority to issue restitution orders and allowed for judicial review of such orders, Felts contended that the district court could now review the Board's order.The district court held that it lacked jurisdiction to review the Board's restitution order. The Utah Court of Appeals affirmed, stating that the legislative amendments did not retroactively grant district courts the authority to review Board-issued restitution orders. The court of appeals concluded that the amendments were intended to clarify and consolidate restitution authority in district courts moving forward, not to provide retroactive judicial review of past Board decisions.The Utah Supreme Court reviewed the case and affirmed the court of appeals' decision. The Supreme Court held that the legislative amendments did not grant district courts the authority to review restitution orders issued by the Board of Pardons and Parole. The court emphasized that the plain language of the amendments did not support Felts's interpretation and that the removal of the prohibition on judicial review of Board restitution orders was for clarity and consistency, not an independent grant of judicial review. The court also noted that Felts could seek relief through an extraordinary writ under rule 65B of the Utah Rules of Civil Procedure, but he had not pursued that option. View "State v. Felts" on Justia Law

The case involves a dispute over a proposed constitutional amendment in Utah, referred to as Amendment D. The amendment, proposed by the Utah State Legislature, seeks to change the state constitution in three significant ways: specifying that the right to alter or reform the government can only be exercised through constitutional processes, banning foreign influence in the initiative and referendum processes, and granting the Legislature unlimited power to amend or repeal any law passed by a citizen initiative. The controversy centers on whether the amendment was properly submitted to voters and whether it was published as required by the Utah Constitution.The Third Judicial District Court in Salt Lake County reviewed the case and found that the Legislature had not complied with the constitutional requirements for submitting and publishing the proposed amendment. The court ruled that the ballot title for Amendment D was misleading and did not accurately reflect the substance of the amendment, thus failing to meet the Submission Clause of the Utah Constitution. Additionally, the court found that the Legislature did not cause the amendment to be published in newspapers across the state for two months preceding the election, as required by the Publication Clause. Consequently, the district court issued a preliminary injunction declaring Amendment D void and ordered that any votes cast on the amendment not be counted.The Utah Supreme Court reviewed the district court's decision and affirmed the preliminary injunction. The Supreme Court agreed that the ballot title was misleading and did not provide voters with a clear understanding of what they were voting for or against, thus violating the Submission Clause. The Court also held that the Legislature failed to comply with the Publication Clause by not ensuring continuous publication of the amendment's text in newspapers for the required two-month period. The Supreme Court concluded that the district court did not abuse its discretion in finding that the balance of harms and the public interest favored issuing the preliminary injunction. As a result, Amendment D was declared void, and any votes cast on it will have no effect. View "League of Women Voters v. Utah State Legislature" on Justia Law

In 2020, Utah law temporarily allowed municipalities to annex unincorporated areas without a petition or county consent. During this period, the Town of Hideout annexed land in Summit County. After receiving a certificate of annexation from the Lieutenant Governor, Summit County challenged the annexation and the related municipal ordinance in district court, claiming procedural violations and seeking to invalidate the annexation.The Fourth Judicial District Court in Wasatch County ruled in favor of Summit County, granting summary judgment on the grounds that Summit County had standing to challenge the annexation and that the annexation ordinance was invalid due to procedural issues. The court found that Summit County had standing under various statutes and the doctrine of public interest standing.The Utah Supreme Court reviewed the case and reversed the district court's decision. The Supreme Court held that Summit County lacked a legally protectible interest under the relevant statutory scheme, which did not provide counties with a right to challenge annexations. The court also determined that the public interest standing doctrine could not compensate for this lack of a legally protectible interest because the legislature had explicitly excluded counties from the annexation process. Consequently, the Supreme Court directed the district court to dismiss the case. View "Hideout v. Summit County" on Justia Law

In 2021, Derek Willden was charged with multiple counts of physical and sexual assault. During trial preparations, the State requested that Willden disclose certain information under Utah Rule of Criminal Procedure 16(b), specifically audio recordings of interviews conducted by Willden’s counsel with witnesses. Willden objected, claiming the recordings were protected as attorney work product and that compelled disclosure would violate both Rule 16(b)(4) and his constitutional rights. The district court disagreed and ordered Willden to turn over the recordings within thirty days. Willden then sought an interlocutory appeal, which the court of appeals granted, and the case was recalled for direct review.The district court, presided over by the Honorable Elizabeth A. Hruby-Mills of the Third District, Salt Lake County, initially ruled in favor of the State’s discovery motion. The court reasoned that the recordings could be redacted to exclude any attorney’s opinions, analysis, or strategy, thus not constituting protected work product. Willden was given thirty days to comply with the order. Before the deadline, Willden petitioned for an interlocutory appeal, which was granted by the court of appeals, and the case was subsequently recalled for direct review by the Utah Supreme Court.The Utah Supreme Court reviewed the case and focused on the interpretation of Rule 16(b) following its 2021 amendment. The court held that the recorded interviews were indeed attorney work product and thus protected from compelled disclosure under Rule 16(b)(4). The court emphasized that the amended rule explicitly protects attorney work product from disclosure, without distinguishing between "core" and "factual" work product. Consequently, the district court’s order was reversed, and the case was remanded for further proceedings. The court did not address Willden’s constitutional arguments, as the case was resolved based on the interpretation of Rule 16(b). View "State v. Willden" on Justia Law

In this case, Tiffany Bingham challenged the constitutionality of the Utah Health Care Malpractice Act’s four-year statute of repose after her medical malpractice claim against Dr. George C. Gourley and Dr. McKay L. Platt was dismissed. Bingham underwent surgeries in 2010, experienced complications, and discovered in 2017 that the surgeries had caused damage, leading to the removal of her kidney. She filed her lawsuit in 2020, more than four years after the alleged malpractice, prompting the dismissal of her claim under the statute of repose.The Fourth District Court in Provo dismissed Bingham’s complaint, concluding that the statute of repose was constitutional. The court found that the statute did not violate the Open Courts Clause, the Uniform Operation of Laws Provision, or the Equal Protection Clause. The court reasoned that the statute was a non-arbitrary means of addressing the social and economic issues related to rising medical malpractice insurance costs and was reasonably necessary to achieve the legislative goal of stabilizing insurance premiums.The Utah Supreme Court affirmed the lower court’s decision. The court held that Bingham failed to demonstrate that the statute of repose violated the Open Courts Clause, as the legislature’s findings of a health care crisis were fairly debatable and the statute was a reasonable means to address that crisis. The court also found that the statute did not violate the Uniform Operation of Laws Provision, as it was reasonably necessary to achieve the legislative goals and actually and substantially furthered those goals. Finally, the court concluded that the statute did not violate the Equal Protection Clause, as it was rationally related to a legitimate public purpose and did not impair a fundamental right. View "Bingham v. Gourley" on Justia Law