Justia Utah Supreme Court Opinion Summaries

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The case involves the interpretation of Utah's Pretrial Justification Statute and its application to a situation where a defendant, Jon Michael Clara, claimed self-defense after firing his gun at a snowplow that had repeatedly rammed his vehicle. Clara was charged with seven counts of felony discharge of a firearm. He invoked the Pretrial Justification Statute, which allows a defendant to have a claim of self-defense assessed by a judge in a pretrial hearing. At the pretrial hearing, the defendant first has to make a prima facie claim of self-defense, then the prosecution must prove by clear and convincing evidence that the defendant’s use of force wasn't justified.At the pretrial hearing, Clara testified that after being rammed multiple times, he believed the snowplow was making a U-turn to attack again, leading him to fire his gun as a warning. The district court ruled that Clara had made a prima facie claim of self-defense and that the State had not disproved the self-defense claim by clear and convincing evidence. Therefore, the district court dismissed the charges against Clara.The State appealed, arguing that Clara failed to make a prima facie claim of self-defense, as the defendant’s belief in the imminence of the threat wasn’t objectively reasonable. The Supreme Court of the State of Utah, however, affirmed the district court’s ruling, stating that a reasonable person in Clara's position could have believed that the snowplow posed an imminent threat. View "State v. Clara" on Justia Law

Posted in: Criminal Law
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This case involved a group of businesses (referred to collectively as Taxpayers) who filed applications for adjustments to the fair market value of their properties for tax year 2020 in the state of Utah. They claimed that their properties' values had decreased due to "access interruption" caused by the COVID-19 pandemic and associated government guidelines, which they argued constituted a circumstance beyond their control under Utah Code section 59-2-1004.6 (the Access Interruption Statute).The Utah State Tax Commission rejected this argument, maintaining that the pandemic did not qualify as an "access interruption event" under the Access Interruption Statute. It reasoned that the statute applies only if access was interrupted due to any of thirteen enumerated events or due to a similar event as determined by the Commission via administrative rule. Because the pandemic neither fit into any of the enumerated categories nor was included in the Commission's administrative rules, the Commission ruled that the statute did not apply.The Supreme Court of the State of Utah agreed with the Commission's reasoning, holding that the Access Interruption Statute allows only the Commission to add to the statute’s list of qualifying circumstances if the Commission determines by rule that the additional event is similar to the events enumerated in the statute. Because the pandemic was not an enumerated event and had not been added by administrative rule, the Supreme Court upheld the Commission's decision. View "Miller Theatres v. Tax Commission" on Justia Law

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A dispute arose between SunStone Realty Partners X LLC (SunStone) and Bodell Construction Company (Bodell) over the postjudgment interest rate applied to a domesticated Hawaii judgment in Utah. Following arbitration in Hawaii over construction defects in a condominium development, SunStone obtained a judgment against Bodell exceeding $9.5 million, which it domesticated in Utah. Bodell requested the Utah court to apply Utah's lower postjudgment interest rate instead of Hawaii's higher one. SunStone opposed this, arguing that the Utah Foreign Judgment Act (UFJA) required the application of Hawaii's rate, or alternatively, that their contract or principles of comity mandated the Hawaii rate.The Supreme Court of the State of Utah affirmed the district court's decision to apply Utah's postjudgment interest rate. The court found that the UFJA, which does not specifically address postjudgment interest, instructs Utah courts to treat a foreign domesticated judgment like a Utah judgment for enforcement purposes. Since postjudgment interest serves, at least in part, as an enforcement mechanism, the UFJA requires the imposition of Utah’s postjudgment interest rate. Further, the construction contract did not require the application of the Hawaii postjudgment interest rate. The court did not consider principles of comity because the UFJA mandates a result. View "Sunstone Realty v. Bodell Construction" on Justia Law

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In this appeal of a criminal case, the Supreme Court of the State of Utah concluded that the police officers' warrantless entry and search of Alexander Hung Tran’s home were reasonable and justified under the emergency aid exception to the Fourth Amendment of the United States Constitution. The court also declined to recognize broader protection under the Utah Constitution in the emergency aid context. The case arose when Tran appealed the district court’s denial of his motion to suppress evidence that police officers obtained during a warrantless entry and search of his home. The officers had entered Tran's home due to their belief that two individuals inside were in need of immediate aid, which was supported by a range of factors. The court held that the totality of the circumstances known to the police officers at the time they entered Tran’s home supported an objectively reasonable basis to believe that the two individuals were in need of immediate aid, thus falling within the emergency aid exception to the Fourth Amendment's warrant requirement. View "State v. Tran" on Justia Law

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In this case, the Supreme Court of the State of Utah considered the appeal of Marianne Tyson who sought to access her sealed adoption records from 1978, in order to learn more about her birth parents' medical histories and any potential health risks. The district court had denied Tyson's petition, interpreting "good cause" as requiring more than a generalized desire to obtain health or genetic information unrelated to a specific medical condition of the petitioner. The district court also held that Tyson's reasons for wanting access to adoption records did not outweigh her birth mother's interest in privacy.The Supreme Court of Utah disagreed with the district court's interpretation of "good cause" and its application of the balancing test. The Supreme Court noted that the legislature did not define "good cause" in the statute and did not impose additional requirements to establish "good cause". The Court held that the district court erred in interpreting the statute to require something more than a general desire to know one's medical history. The Supreme Court also found that the district court did not properly balance the interests under the Utah Rule of Civil Procedure 107, as it focused solely on the birth mother’s privacy interests and did not consider Tyson's reasons for wanting to see her adoption records.The case was remanded back to the district court to reassess Tyson's petition under the correct standard. The district court must evaluate Tyson's petition under a correct interpretation of "good cause" and conduct a proper balancing test, giving weight to both the birth mother’s privacy interests and Tyson's reasons for wanting to see her adoption records. View "In re Adoption of M.A." on Justia Law

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In the medical malpractice case concerning the withdrawal of life-sustaining treatment from Lillian Birt, her daughter Jenafer Meeks sued the treating doctors, Wei Peng and Christina G. Richards, both individually and on behalf of Ms. Birt's heirs and estate. The children of Ms. Birt had decided to discontinue her life support based on the misinformation they received from the doctors about her condition. The doctors inaccurately portrayed her condition as terminal, leading the children to believe that the treatment was only prolonging her life unnaturally. However, Ms. Birt's condition was not terminal, and there was a high probability of her recovery if the treatment had continued.In the Supreme Court of the State of Utah, the doctors appealed on two issues. Firstly, they argued that the trial court's jury instruction 23 was incorrect as it did not explicitly state that Ms. Meeks had the burden to prove the standard of care. Secondly, they contended that the lower court erred in denying their motion for judgment as a matter of law on the survival claim due to lack of evidence that Ms. Birt experienced pain and suffering in the hours between the doctors' negligence and her death.The Supreme Court held that the trial court correctly instructed the jury that Ms. Meeks had the burden to prove the standard of care, as the instruction implicitly required the jury to determine the standard of care as part of proving a breach of it. However, the Supreme Court agreed with the doctors that Ms. Meeks failed to provide evidence of Ms. Birt's experience of pain, suffering, or inconvenience during the period between the doctors' negligence and her death. Therefore, the Supreme Court affirmed in part and reversed in part the decision of the lower court. View "Peng v. Meeks" on Justia Law

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In the case at hand, Robert Evan Woodham was convicted for failing to yield to stationary emergency vehicles in violation of Utah Code subsection 41-6a-904(2). The conviction was upheld by the district court, after which Woodham appealed to the Utah Court of Appeals. However, the appellate court dismissed his appeal for lack of jurisdiction, citing that the district court did not rule on the constitutionality of a statute or ordinance, which is a requirement for appellate review under Utah Code § 78A-7-118(11). Woodham then petitioned the Supreme Court of Utah, arguing the district court implicitly ruled on his constitutional argument.The Supreme Court of Utah clarified that an implicit ruling by the district court on the constitutionality of a statute or ordinance is sufficient to permit appellate review under Utah Code subsection 78A-7-118(11), overruling a contrary holding by the Utah Court of Appeals in Murray City v. Timmerman. However, the Court agreed with the appellate court's decision in Woodham's case, stating that he did not preserve a constitutional challenge to the emergency vehicle statute, and therefore, the district court did not implicitly rule on its constitutionality. Consequently, the dismissal of Woodham's appeal due to lack of jurisdiction was affirmed. View "Park City v. Woodham" on Justia Law

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In this case, a doctor, Dr. Gabriel Fine, sued the University of Utah School of Medicine, alleging that the University deprived him of his clinical privileges without following the procedures required by its bylaws. The University moved for summary judgment, pointing to a provision in its bylaws where Dr. Fine had agreed not to sue "for any matter relating to appointment, reappointment, clinical privileges, or the individual’s qualifications for the same." The district court granted summary judgment in favor of the University, agreeing that Dr. Fine had released his claims against the University.Dr. Fine appealed the decision, arguing that the district court erred in interpreting the release to apply to his case. He asserted that the release only applied to actions taken during a formal review process and his claims arose from actions taken during an informal process.The Supreme Court of the State of Utah disagreed with Dr. Fine's argument. The court interpreted the release using its traditional tools of contract interpretation and found no textual justification for limiting the release's application only to actions taken during the formal review process. The court held that Dr. Fine’s claims against the University fell within the scope of the release and therefore affirmed the district court's decision. View "Fine v. University of Utah" on Justia Law

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In a case before the Supreme Court of the State of Utah, the petitioner, Elbert John Paule, was charged with murder, obstruction of justice, reckless endangerment, and assault following a fatal shooting incident involving a friend. The jury acquitted Paule on all charges except obstruction of justice. Paule challenged his conviction, arguing that the obstruction of justice conviction was legally inconsistent with the jury’s determination that he was not guilty of the other crimes. The Utah Court of Appeals affirmed the conviction. On certiorari review, the Supreme Court of the State of Utah affirmed the lower court's ruling.The Supreme Court held that to be convicted of obstruction of justice, a defendant need only perform an obstructive act with the requisite intent. Proof of a separate crime is not necessary. The court concluded that because a violation of Utah’s obstruction of justice statute requires only that a defendant act with the requisite intent—it does not require proof of a separate criminal offense—the jury’s verdict was not legally impossible. Furthermore, the court found that Paule's counsel was not constitutionally ineffective in failing to seek a more detailed unanimity instruction. View "State v. Paule" on Justia Law

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In this case, Cathy McKitrick, an investigative journalist, sought access to certain records under the Government Records Access and Management Act (GRAMA). The Ogden City Records Review Board ordered the city to release redacted versions of the records. Kerry Gibson, the subject of the records, petitioned the district court to prevent their release. McKitrick intervened in the proceedings and moved to dismiss Gibson's petition for lack of standing. The Supreme Court of the State of Utah held that Gibson lacked standing. Before the district court dismissed the case, McKitrick moved for an award of attorney fees and litigation costs, which was denied by the district court. On appeal, the Supreme Court of the State of Utah reversed the district court’s interpretation of the fee provision but did not hold that McKitrick was entitled to a fee award. Because the district court did not consider substantive aspects of the fee provision, the Supreme Court remanded the case for it to do so. View "McKitrick v. Gibson" on Justia Law