Justia Utah Supreme Court Opinion Summaries

An employee filed a workers’ compensation claim with the Utah Labor Commission, alleging significant injuries, including complex regional pain syndrome, sustained while working for her employer. As part of the claim process, she was ordered by an administrative law judge (ALJ) to attend independent medical examinations (IMEs) with three different physicians selected by her employer. Each exam failed to be completed due to disputes or complications involving her cooperation, including refusal to sign paperwork, attempts to record the exam, and disagreements over exam conditions.The employer moved for sanctions after repeated failed IMEs. The ALJ found that the employee and her attorneys had hindered the employer’s right to conduct a medical exam and dismissed her claim, also ordering her attorneys to pay the resulting costs. On appeal, the Labor Commission Appeals Board initially reversed the dismissal, ruling that the statutory sanction for obstructing an IME is suspension of the claim, not dismissal. However, after a third failed exam, the Board changed its position, concluding that the employee’s pattern of obstruction warranted dismissal under rule 37 of the Utah Rules of Civil Procedure and imposed monetary sanctions on her attorneys.The Supreme Court of the State of Utah reviewed the case on certification from the Court of Appeals. The court held that dismissal is not an available sanction for obstructing a medical examination under Utah Code section 34A-2-602(2); instead, the only permissible sanction is suspension of the claim during the period of obstruction. The court also found that the employee herself did not have standing to challenge the monetary sanctions imposed on her attorneys. The court reversed the Board’s order dismissing the claim but left the monetary sanctions undisturbed, to be challenged by the proper party. View "Hooker v. Labor Commission" on Justia Law

A defendant convicted of aggravated murder sought postconviction relief under Utah’s Post-Conviction Remedies Act (PCRA), alleging prosecutorial misconduct and ineffective assistance of counsel. The Third District Court granted summary judgment to the State and dismissed the PCRA petition in March 2019. The defendant did not appeal the dismissal within the prescribed period and subsequently sought habeas corpus relief in federal court, which was denied in part due to the failure to exhaust state remedies by not appealing the PCRA dismissal.In January 2024, nearly five years after the PCRA dismissal, the defendant moved the Third District Court to reinstate the thirty-day appeal period, arguing that PCRA proceedings should be treated as “quasi-criminal” and therefore governed by Utah Rule of Appellate Procedure 4(f), which at the time had no time limit, rather than Rule 4(g), which imposes a one-year limit for civil cases. The State opposed, citing statutory language that PCRA proceedings are civil and that the motion was untimely under Rule 4(g). The district court agreed, finding PCRA actions are civil for purposes of Rule 4 and denied the motion as untimely.The Supreme Court of the State of Utah reviewed the district court’s denial of the motion to reinstate. The Court held that the appellant had not demonstrated error in the district court’s application of Rule 4(g), as his briefing failed to engage with the district court’s reasoning or show why PCRA appeals should be treated as criminal under Rule 4(f). The Court also declined to address the appellant’s constitutional arguments concerning deadlines for postconviction appeals because those issues were not properly preserved below. Accordingly, the Supreme Court affirmed the district court’s denial of the motion to reinstate the appeal period. View "Reyos v. State" on Justia Law

The underlying dispute arose from a business relationship between Standard Fiber, LLC and entities associated with Ridgeview, involving management fee arrangements over several years. In 2006, Standard Fiber and Ridgeview Capital, LLC entered a Management Services Agreement (2006 MSA) with a set fee structure. While payments continued after the 2006 MSA expired, the parties disagreed on what terms governed post-2008 payments. Standard Fiber asserted that subsequent agreements, including a 2014 agreement to pay $25,000 per month, controlled. Ridgeview denied the existence or effect of any later agreements, instead claiming entitlement to fees under the original MSA or an alleged oral 50/50 fee-splitting agreement.Ridgeview sued in the Third District Court, Salt Lake County, seeking unpaid management fees under the 50/50 oral agreement. The court compelled arbitration pursuant to the parties’ operating agreement, and the arbitration proceeded before a JAMS arbitrator. Ridgeview’s arbitration demand asserted claims for fees under the 2006 MSA and the 50/50 Agreement, but did not seek relief for breach of the 2014 fee agreement. During the arbitration, Standard Fiber referenced the 2014 Agreement as a defense, but Ridgeview did not advance it as a basis for affirmative recovery. The arbitrator ultimately found against Ridgeview on its submitted claims but awarded damages to Ridgeview based on breach of the 2014 Agreement.Standard Fiber moved the district court to modify or vacate the arbitration award, arguing the arbitrator exceeded her authority by granting relief on an unsubmitted claim. The district court confirmed the award, concluding it was rationally related to the parties’ submissions. On appeal, the Supreme Court of the State of Utah held that an arbitrator may only award relief on claims actually submitted for decision. Because Ridgeview did not submit a claim for breach of the 2014 Agreement, the arbitrator exceeded her authority. The Supreme Court reversed the district court’s confirmation of the award and remanded for modification to exclude any amount based on the 2014 Agreement. View "RV Holdings 4 v. Standard Fiber" on Justia Law

Derek Anderson sought to incorporate a new town called West Hills in Summit County, Utah, along Highway 248. To comply with Utah’s municipal incorporation code, Anderson followed a process involving proposals, notices, hearings, and multiple boundary adjustments. The incorporation procedure allows certain landowners, defined as "specified landowners" based on property size or value, to request exclusion from the proposed municipality during two specific windows: after initial notice and after the first public hearing. Anderson modified the proposed boundaries several times, and in doing so added some landowners after both opt-out windows had closed, depriving them of the statutory opportunity to request exclusion.Summit County’s Third District Court reviewed the case after these landowners, including Jennifer McCaffrey and others, sued to stop the incorporation election. They argued that the incorporation code violated the Uniform Operation of Laws Clause of the Utah Constitution by allowing some landowners to request exclusion while denying this right to others who were added later. The district court applied rational basis review and found that the code’s classification failed this standard, reasoning that the timing for boundary locking was arbitrary and allowed sponsors to manipulate which landowners had exclusion rights. The court granted summary judgment to the landowners and enjoined the Lieutenant Governor from certifying the incorporation petition.The Supreme Court of the State of Utah reviewed the appeal. The Court held that, under rational basis review, the legislative scheme for exclusion rights was constitutional. It found that the statutory cutoff for opt-outs was a reasonable means to ensure finality and prevent endless boundary modifications, and that the classification had a rational connection to legitimate legislative objectives. The Court reversed the district court’s ruling and reinstated the Lieutenant Governor’s certification of the incorporation petition for the 2026 general election. View "McCaffrey v. Anderson" on Justia Law

After the first day of a criminal trial for aggravated assault, the presiding judge disclosed that he was related by marriage to one of the State’s witnesses. The defendant then moved to disqualify the judge, citing concerns about public perception of impartiality. The motion was referred, as required, to the district’s presiding judge, who granted it, vacated the trial, and transferred the case to another judge without giving the parties an opportunity to object. The jury was excused, and the proceedings were reassigned.Subsequently, the State amended the charges and sought an expedited trial before the new judge. Before the new trial began, the defendant moved to dismiss, arguing that retrial was barred by Utah’s double jeopardy protections since the jury had been discharged without either his consent or a showing of legal necessity. The new trial judge denied the motion, finding that the circumstances made the mistrial legally necessary because there were no reasonable alternatives, primarily due to logistical difficulties in promptly reassigning the case to another judge. The defendant appealed.The Utah Court of Appeals reversed, holding that the legal necessity exception to double jeopardy could not apply because the parties had not been afforded an opportunity to object before the mistrial was declared. The court of appeals concluded that this omission alone barred retrial.On certiorari, the Supreme Court of the State of Utah held that failing to afford the parties an opportunity to object before declaring a mistrial does not, by itself, preclude application of the legal necessity exception to Utah’s double jeopardy protection. The court explained that if the record shows there were no reasonable alternatives to a mistrial under the circumstances, retrial is not barred, even without an opportunity to object. The court reversed the decision of the court of appeals and remanded for further proceedings to determine whether reasonable alternatives existed. View "State v. Mitton" on Justia Law

After an evening of heavy drinking and marijuana use, the appellant shot and killed Randy Lewis, who was unarmed, during an escalating argument at a friend’s home. The appellant claimed that he acted in self-defense, stating that the victim had threatened him and may have reached for a knife, although no physical evidence supported the presence of a weapon. The appellant fled the scene, later sent a deceptive message to the friend, and gave inconsistent accounts of the incident to various people.The case was first tried in the Second District Court, Davis County. The State charged the appellant with murder and felony firearm possession for having a gun while under the influence of marijuana. At trial, the appellant’s counsel argued that the self-defense statute should not bar his claim unless he was committing a “forcible felony,” or that the statute’s application would violate the Utah Constitution. The district court rejected these arguments, instructing the jury that self-defense was unavailable if the defendant was committing any felony. The jury convicted the appellant of murder and felony firearm possession but acquitted him of aggravated assault. On direct appeal, the appellant’s counsel challenged the jury instruction but failed to argue prejudice, and the Utah Court of Appeals affirmed because prejudice was not shown.The appellant then sought postconviction relief, arguing ineffective assistance of trial and appellate counsel. The postconviction court granted summary judgment for the State, finding no prejudice due to overwhelming evidence of guilt. On appeal, the Supreme Court of the State of Utah affirmed. The court held that, even if the jury instructions had been different, there was not a reasonable likelihood of a more favorable result for the appellant, given the evidence against him. Thus, the appellant failed to demonstrate prejudice, and his ineffective assistance of counsel claims did not succeed. View "Fenstermaker v. State" on Justia Law

The defendant pled guilty to aggravated kidnapping based on unlawful detention and was sentenced in the Third District Court, Salt Lake County, to fifteen years to life in prison. After his sentencing, but while his direct appeal was pending, the Utah legislature amended the relevant statute, reducing the penalty for his offense from a first-degree to a third-degree felony. The defendant then sought resentencing under the new, lesser penalty, arguing that the common law amelioration doctrine entitled him to the benefit of the statutory reduction because his case was not yet final.Previously, the Utah Court of Appeals had remanded the case for resentencing after determining that the State breached the plea agreement; on remand, the district court imposed the same sentence. The defendant’s subsequent appeal resulted in affirmance of his sentence. Only after the appellate court’s decision, and after the statutory reduction had been enacted, did he move for resentencing under Utah Rule of Criminal Procedure 22(e). The district court denied his motion, reasoning that Utah law bases sentencing on the statute in effect at the time of sentencing, not on subsequent amendments, even if the case is still on appeal.The Supreme Court of the State of Utah reviewed the case. It held that under Utah’s general savings statute, a criminal penalty is “incurred” at the time of sentencing. Therefore, any statutory reduction enacted after sentencing does not apply, even if the defendant’s direct appeal is still pending. The court concluded that the amelioration doctrine, which would allow application of the lesser penalty before a case is final, is inconsistent with the statute and Utah precedent. As a result, the court affirmed the district court’s denial of resentencing and upheld the original sentence. View "State v. Featherston" on Justia Law

After two children lost their parents in a helicopter accident, their maternal and paternal grandmothers were appointed as coguardians. Over time, the relationship between the grandmothers deteriorated, leading the paternal grandparents to file a petition to adopt the children. The maternal grandmother intervened in that proceeding, then, together with her husband, filed a separate adoption petition. The paternal grandmother received proper legal notice of this competing adoption proceeding, which warned her that she needed to intervene within thirty days if she wished to contest the adoption or risk losing all rights regarding the children. Despite this notice, she did not file a motion to intervene.The Eighth District Court consolidated the cases briefly, then separated them to proceed independently. After deconsolidation, the maternal grandparents served notice again, but the paternal grandmother still did not intervene. The maternal grandmother moved for partial summary judgment, arguing that the paternal grandmother should be barred from pursuing her adoption petition due to her failure to intervene. The district court agreed and barred both paternal grandparents from proceeding. The paternal grandmother petitioned for interlocutory review, and the Utah Court of Appeals reversed, holding that barring the paternal grandmother but not the paternal grandfather from maintaining their petition produced an absurd result, given the statutory scheme.The Supreme Court of the State of Utah reviewed the case and reversed the appellate court’s decision. It held that the plain language of the Utah Adoption Act’s intervention provision requires a person who receives notice of an adoption proceeding and wishes to contest it to intervene within thirty days, or forfeit all rights to the adoptee, including the ability to bring or maintain any related action. The court found that the appellate court’s application of the absurdity doctrine was based on a hypothetical scenario, not the actual district court ruling, and concluded that the statutory result was not so overwhelmingly absurd as to justify departure from the statute’s plain language. The Supreme Court affirmed the district court’s summary judgment. View "In re Adoption of R.P." on Justia Law

A fatal collision occurred when a Volkswagen Jetta, driven by Raul Lopez with Emilio Martinez-Arroyo as a passenger, rear-ended a utility trailer owned by Ron J. Peterson Construction, Inc. (RJP) on a Utah highway. The trailer, which was transporting construction equipment and did not have underride protection, was traveling significantly below the speed limit with its emergency flashers on. Both occupants of the Jetta died instantly after their car slid under the trailer. Yesneiri Maldonado-Velasquez, the decedent’s wife, sued RJP alleging negligence both in operating the vehicle and in using a trailer that lacked safety features that could have mitigated the injuries.In the Third District Court, Summit County, RJP moved for summary judgment, arguing that it had no duty to upgrade the trailer beyond federal safety standards and that the crash was solely caused by Lopez. The district court found a general statutory duty to operate safe equipment but determined that there was no specific duty to alter the trailer, based on federal preemption and application of factors from B.R. ex rel. Jeffs v. West. As a result, the court excluded much of the plaintiff's expert testimony on enhanced injury and trailer design, allowing only claims related to negligent operation. The jury ultimately found RJP not at fault.On direct appeal, the Supreme Court of the State of Utah held that the district court erred by applying the Jeffs factors to narrow an already established broad statutory duty to operate safe vehicles. The Supreme Court clarified that federal regulations set a minimum standard, not a ceiling, and that state law may impose greater obligations unless direct conflict preemption applies. The court also held that the exclusion of expert testimony premised on the erroneous duty ruling was an abuse of discretion. The Supreme Court reversed and remanded for further proceedings consistent with its opinion. View "Maldonado-Velasquez v. Ron J Peterson Construction" on Justia Law

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