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The Supreme Court affirmed the judgment of the court of appeals affirming the conviction of Defendant for the murder of his wife. During trial, Defendant sought to reduce the conviction from murder to manslaughter by establishing special mitigation through extreme emotional distress. The jury rejected Defendant’s arguments for special mitigations. On appeal, Defendant argued that the jury instructions concerning extreme emotional distress were in error. The court of appeals affirmed. The Supreme Court agreed, holding (1) a criminal defendant who seeks to establish special mitigation by extreme emotional distress must prove that his loss of self-control is reasonable; and (2) under the circumstances of this case, the jury instructions accurately described the law. View "State v. Lambdin" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the district court’s grant of partial summary judgment in favor of Hadley Christensen, who claimed reimbursement pursuant to Utah Code 52-6-201 from Juab School District, his former employer, for attorney fees and costs incurred in a successful defense against charges of aggravated sexual abuse of a child. The district court awarded judgment pursuant to a stipulation entered by the parties. The Supreme Court held (1) the reimbursement statute provides reimbursement for the successful defense against an information filed in connection with the acts of a public officer or employee; (2) under the reimbursement statute, Christensen was entitled to reimbursement; and (3) Christensen was charged under color of authority as a person in a position of special trust, a prong in the reimbursement statute. View "Christensen v. Juab School District" on Justia Law

Posted in: Criminal Law

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The Supreme Court reversed the district court’s denial of the motion to dismiss the lawsuit brought by several property developers (Developers) alleging that the City of West Jordan violated statutory provisions that regulate how a municipality may spend impact fees collected from developers. The court held (1) Developers had standing to challenge the constitutionality of the impact fees they were assessed; (2) Developers failed to state a takings claim for which relief can be granted because Developers’ allegations that West Jordan either failed to spend impact fees within six years or spent the fees on impermissible expenditures were inadequate to support a constitutional takings claim; and (3) Developers did not have standing to bring a claim in equity. View "Alpine Homes, Inc. v. City of West Jordan" on Justia Law

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The juvenile court erred in using a per se rule that “[h]itting a child with a belt or strap or another object is abuse” because the rule is overbroad and alters the statutory meaning of “abuse” within the meaning of the Utah Code. This case involved four children. Mother was the mother of all four children, and Father was the biological father of the younger two. The State filed a petition seeking to adjudicate the children as abused and neglected under Utah Code 78A-6-105. The parties stipulated to a number of findings of fact. The juvenile court determined that Parents abused the children under section 78A-6-105. Parents appealed, arguing that the juvenile court erred when it concluded that spanking a child with a belt, without any additional proof of harm, constitutes abuse within the meaning of Utah law. The Supreme Court agreed, holding that the stipulated facts did not support an abuse determination. View "In re K.T." on Justia Law

Posted in: Family Law

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In this dispute over a mining road built on Flagstaff Mountain over a century ago, Plaintiffs sued Defendants, the owners of land traversed by the road, asserting a right to use the road as a public highway under the Mining Act of 1866 and the 1880 Utah Highway Act and also under a common law prescriptive easement claim. The district court granted summary judgment for Defendants and denied Plaintiffs’ motion for leave to file a second amended complaint. The Supreme Court affirmed, holding (1) Plaintiffs’ public road claim failed because Plaintiff did not present sufficient evidence of the road’s public use for a sufficient period of time; (2) Plaintiffs' common law prescriptive easement claim failed because Plaintiffs’ arguments on appeal were not preserved for appellate review; and (3) the court owed deference to the district court’s determination that the potential delay in proceedings was sufficient to defeat the presumption in favor of amendment. View "Stichting v. United Park City Mines Co." on Justia Law

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The Supreme Court reversed the district court’s order granting Defendant’s motion to suppress evidence obtained incident to his arrest. The district court concluded that the law enforcement officer who stopped Defendant’s vehicle for an improper lane change violated Defendant’s Fourth Amendment rights when he asked to see Defendant’s identification and ran a warrants check without reasonable suspicion that Defendant had committed or was about to commit a crime. The Supreme Court disagreed, holding (1) to promote officer safety, the Fourth Amendment does not prevent an officer from asking a passenger to produce identification and running a warrants check so long as that does not unreasonably prolong the duration of the stop; and (2) in this case, the officer’s seconds-long extension of the lawful traffic stop did not unreasonably prolong the detention. View "State v. Martinez" on Justia Law

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In a number of cases pending before several district courts concerning ownership of certain rights of way claimed by the State of Utah and several of its counties, the federal courts asked the Utah Supreme Court to determine whether Utah Code 78B-2-201(1) and its predecessor are statutes of limitations or statues of repose. The Supreme Court held that the plain language of both versions of the statute reveals them to be statutes of repose. However, because of the absurdity that results from applying section 201 and its predecessor as statutes of repose in the context of the State’s Revised Statute 2477 rights of way, leading to the result that the State lost title to any such rights of way after seven years without any opportunity to prevent such loss, the court construed these statutes as statutes of limitations when applied to the State’s Revised Statute 2477 right of way claims. View "Garfield County v. Southern Utah Wilderness Alliance" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals, which set aside the order of the Labor Commission concluding that Respondent had failed to make out a permanent total disability claim against her former employer, the University of Utah Huntsman Cancer Hospital. The Commission reversed the order of an administrative law judge (ALJ), which awarded Respondent permanent total disability benefits. In denying Respondent’s application for permanent total disability benefits, the Commission concluded that Respondent had failed to show that she was limited in her ability to do basic work activities. The court of appeals reversed, concluding that Respondent was not limited in her ability to perform basic work activities because her impairments did not “reasonably” limit her. The Supreme Court disagreed and affirmed the Commission’s order denying Respondent’s application for permanent total disability benefits, holding (1) both the court of appeals and the Commission misstated the burden of proof on the “other work reasonably available” element of a permanent total disability claim; and (2) the court of appeals erred in reversing the Commission’s determination that Respondent was limited in her ability to do basic work activities. View "Quast v. Utah Labor Commission" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals reversing the order of the Labor Commission denying Respondent’s application for permanent total disability benefits under Utah Code 34A-2-413, the permanent total disability portion of the Workers’ Compensation Act. The Commission denied the application based on Respondent’s failure to prove two elements of a permanent total disability claim. The Supreme Court held (1) the court of appeals erred in its interpretation of section 34A-2-413(1)(c)(ii); (2) the court of appeals misallocated the burden of proof and improperly considered information not contained in the record in reversing the Commission’s determination that Respondent failed to prove the “essential functions” element of a permanent total disability claim; and (3) the Commission correctly denied Respondent’s application for permanent total disability benefits. View "Oliver v. Utah Labor Commission" on Justia Law

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The Supreme Court affirmed the district court’s dismissal of Plaintiff’s claims seeking a declaration that Utah Code 63G-7-601 and 78B-3-104 violate the Open Courts Clause of the state Constitution by restricting access to courts in lawsuits against police officers. The district court dismissed the claims on summary judgment, concluding that Plaintiff lacked traditional standing to challenge these statutory provisions and, alternatively, that his claims failed on the merits. The Supreme Court affirmed without endorsing the merits of the district court’s standing analysis or its alternative consideration of the merits, holding that Defendant failed to carry his burden on appeal of challenging the district court’s standing decision. View "Kendall v. Olsen" on Justia Law

Posted in: Criminal Law