Justia Utah Supreme Court Opinion Summaries

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The Supreme Court reversed the judgment of the district court issuing an injunction enjoining the implementation of Senate Bill 78 (SB 78) on the grounds that it violates article X, section 8 of the Utah Constitution, holding that State Board of Education members are not employed in the state's education systems and are therefore not covered by article X, section 8. In 2016, the legislature passed SB 78, which makes the office of State Board of Education a partisan office and requires Board members to be elected through the general partisan election process. The district court concluded that Board members hold "employment" in a legal sense in the State's education system and therefore fell within the purview of article X, section 8. Thus, the court concluded, SB 78 was unconstitutional. The Supreme Court reversed the district court and reinstated SB 78, holding that because the Utah Constitution omits Board members from being in a condition of employment in the state's education systems, SB 78 does not violate the Utah Constitution. View "Richards v. Cox" on Justia Law

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The Supreme Court accepted certified questions of law from the federal court related to a case involving artificial hip implants, answering to what extent implanted medical devices should be immune from strict liability design defect claims under Utah law because they are "unavoidably unsafe," meaning they are "incapable of being made safe for their intended and ordinary use" but their marketing and use is justified because of the benefit they provide. Specifically, the Court answered (1) while some implanted medical devices are unavoidably unsafe, under current federal regulations, this question should be treated as an affirmative defense and determined by the fact-finder on a case-by-case basis with regard to devices that enter the market through the 510(k) process; and (2) for devices that go through a more rigorous premarket approval process, the Court does not opine on whether such devices might be unavoidably unsafe as a matter of law because they are already exempt from design defect claims under the United States Supreme Court's decision in Riegel v. Medtronic, Inc. 552 U.S. 312 (2008). View "Burningham v. Wright Medical Technology, Inc." on Justia Law

Posted in: Products Liability

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The Supreme Court affirmed the award of benefits entered by the Utah Labor Commission in favor of Jessica Wilson, holding that the Commission did not err in concluding that Wilson's injuries arose out of, and in the course of, her employment with her employer, Intercontinental Hotels Group (IHG). Wilson sustained injuries after tripping and falling in a parking lot while walking into work. Wilson requested benefits from IHG. IHG denied Wilson's claim, concluding that, under the going-and-coming rule, Wilson's accident did not arise out of and in the course of her employment. An ALJ with the Commission reviewed Wilson's claim and concluded that Wilson was entitled to benefits under the premises rule. The Commission affirmed, concluding that the communal parking area where the accident occurred was proof IHG's premises for purposes of determining compensability. The Supreme Court affirmed, holding that the Commission properly determined that Wilson's accident occurred on IHG's premises and that, under case law, this constituted an accident in the course of her employment. View "Intercontinental Hotels Group v. Utah Labor Commission" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions for aggravated kidnapping, aggravated robbery, and obstruction of justice, holding that the court of appeals properly concluded that Defendant's free will was not overborne in confessing and making other incriminating statements to the police and properly concluded that a jury instruction given at trial was faulty but did not result in prejudice to Defendant. On appeal, Defendant argued that the court of appeals erred in (1) affirming the trial court's determination that his statements were admissible at trial as impeachment evidence, despite a violation of his Miranda rights, which barred the statements from being used in the Sate's case-in-chief; and (2) erred in affirming his conviction for aggravated robbery despite a jury instruction that incorrectly recited the requisite mental state for the offense. The Supreme Court affirmed, holding (1) the court of appeals correctly affirmed that Defendant's statements to police were voluntary and that his confession and incriminating statements could be used for impeachment purposes in the event that Defendant chose to testify; and (2) the faulty jury instruction did not affect the outcome or the verdict. View "State v. Apodaca" on Justia Law

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In answer to three questions certified to it by the federal district court the Supreme Court answered, among other things, that a Utah state district court does not have appellate jurisdiction to review the Utah County Board of Commissioners' decision upholding a fine levied under Utah Code 20A-11-1205. Steven Downs, the Public Information Officer for the City of Orem, was fined for violating the Political Activities of Public Entities Act, specifically, section 20A-11-1205(1)(b), which stated that "a person may not send an email using the email of a public entity...to advocate for or against a ballot proposition." The Board of Commissioners voted to uphold the fine. Downs filed a petition in the federal district court challenging the ruling on several grounds. The federal court reserved ruling on a number of motions until receiving guidance on the three questions certified to the Supreme Court. The Court answered (1) section 20A-11-1205 does not convey appellate jurisdiction on state district courts; (2) the term "ballot proposition" as used in section 20A-11-1205(1) includes the entire referendum process; and (3) a "ballot proposition" as used in section 21A-11-1205(1) includes the entirety of the referendum process even if the challenged local government action is later found to be administrative in nature and therefore not subject to a referendum. View "Downs v. Thompson" on Justia Law

Posted in: Election Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing Appellant's motion for declaratory judgment, holding that Utah Code 77-41-105 requires individuals to register as a sex offender in Utah even though their conviction in another jurisdiction has been set aside. Appellant pled guilty in Idaho to a sex offense that required him to register as a sex offender. The entry of judgment was withheld, and after Defendant completed his probation, the court set aside Defendant's plea. When Defendant moved to Utah he filed a lawsuit seeking a declaratory judgment that he was not required to register in Utah because he was never actually convicted in Idaho. The district court dismissed the suit. The court of appeals affirmed, holding that section 77-41-105(3)(a) required Defendant to register regardless of whether he was convicted because he met the definition of an "offender." The Supreme Court affirmed, holding (1) Appellant was required to register as a sex offender in Utah based on his status as an offender; and (2) Appellant was required to register in Utah because he was convicted in Idaho. View "Holste v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court reversed the judgment of the district court ruling against Appellant in this declaratory judgment action and holding that the Office of Recovery Services (ORS) was entitled to recover from the portion of Appellant's settlement award representing all medical expenses, both past and future, holding that ORS may recover from only that portion of an award representing past medical expenses. Appellant brought malpractice and negligence claims against a hospital, alleging that the hospital's failure to diagnose his stroke caused severe injuries. At the time of his injuries, Appellant received Medicaid through the State, and Medicaid paid for Appellant's treatment. At issue here was what portion of Appellant's settlement award the ORS was permitted to collect. The district court held that ORS was entitled to recover from the portion of Appellant's settlement award representing all medical expenses, both past and future. The Supreme Court disagreed and remanded the case, holding that ORS may place a lien on and recover from only that portion of Appellant's settlement representing past medical expenses. View "Latham v. Office of Recovery Services" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing Plaintiff's claims against the Iron County attorney, holding that Plaintiff failed to demonstrate that a previous federal court order dismissing Plaintiff's official-capacity claims against the same defendant with prejudice lacked preclusive effect. Plaintiff filed suit in federal district court asserting claims against several defendants, including the Iron County attorney in his official capacity. The federal court dismissed the claims with prejudice. Plaintiff refiled her suit in state court, alleging state constitutional violations against several defendants, including the Iron County attorney. The district court dismissed the case with prejudice, concluding that Plaintiff's claims were barred by res judicata. The court of appeals affirmed. The Supreme Court affirmed, holding that Plaintiff failed to rebut the presumption that the federal court order was "on the merits" for purposes of the claim preclusion doctrine. View "Cheek v. Iron County Attorney" on Justia Law

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The Supreme Court affirmed the post-conviction district court's conclusion that appellate counsel's performance did not prejudice Appellant, holding that Appellant was not prejudiced by his appellate counsel's failure to investigate the alleged ineffective assistance of Appellant's trial counsel. Appellant was conviction of aggravated murder and attempted aggravated murder. After a direct appeal, Appellant filed a petition seeking relief under the Post-Conviction Remedies Act, alleging that his trial counsel and appellate counsel were both constitutionally deficient. After a remand, the district court concluded that appellate counsel's performance was deficient because she had failed to investigate certain arguments while preparing the appeal but that Appellant was not prejudiced because his trial counsel had not rendered ineffective assistance. The Supreme Court affirmed, holding (1) this Court may consider the evidence entered into the record during the proceedings below; and (2) the district court correctly concluded that Appellant did not suffer prejudice as a result of his appellate counsel's deficient performance. View "Ross v. State" on Justia Law

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The Supreme Court affirmed the decision of the district court dismissing Plaintiff's medical malpractice claim against the University of Utah, holding that the district court properly found that Plaintiff's notice of claim was untimely. Plaintiff sought damages for injuries she suffered during a surgery performed by a University of Utah School of Medicine professor at LDS Hospital. Under the Utah Governmental Immunity Act (UGIA), Plaintiff was required to give notice of her claim to the State within one year of the date Plaintiff knew or should of known that she had a claim against a State entity or employee. On appeal, Plaintiff argued that her notice of claim was timely because it was filed within one year of when she knew or should have known she had a claim against the University. The Supreme Court disagreed, holding (1) Plaintiff had sufficient information to put a reasonable person on notice that her claim might be against the State, instead of LDS Hospital; (2) because Plaintiff had reason to inquire long before she filed her notice of claim, her notice was untimely under the UGIA; and (3) Plaintiff's arguments based on the doctrine of res judicata and the Open Courts provision of the Utah Constitution were without merit. View "Amundsen v. University of Utah" on Justia Law

Posted in: Personal Injury