Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals holding that the conduct of two court personnel while sharing a nonpublic courthouse elevator with a jury during trial triggered a rebuttable presumption of prejudice against Defendant, holding that the court of appeals did not err.The court personnel in this case - a uniformed highway patrolman and a court IT technician - told the jurors, in so many words, to find Defendant guilty and to "hang him." The trial court bailiff also stood in the elevator but did not intervene in the exchange. The court of appeals reversed Defendant's conviction and remanded the case for a new trial. The Supreme Court affirmed, holding that the impermissible contact violated Defendant's right to an impartial jury and triggered a rebuttable presumption that Defendant was prejudiced as a result. The Court remanded the case to the district court for a determination of whether the State met its burden to rebut this presumption. View "State v. Soto" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals upholding the decision of the Utah Procurement Policy Board to dismiss ICS Corrections, Inc.'s appeal of the decision of the Utah Division of Purchasing and General Services to award a multi-year telecommunications contract to another bidder, holding that the Board neither clearly erred nor acted arbitrarily or capriciously in dismissing ICS's appeal on the basis that it failed to attach a copy of the protest decision to its notice of appeal within the appeal deadline.In declining to disturb the Board's decision, the court of appeals held that the statutory requirements outlined in the pertinent provision of the Utah Procurement Code compelled strict compliance with their terms. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the Legislature has unequivocally required the Board to dismiss an appeal where the appellant has failed to attach a copy of the protest decision to its notice of appeal within the appeal deadline; and (2) therefore, ICS's appeal must be dismissed. View "ICS Corrections, Inc. v. Procurement Policy Board" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing this case claiming that the Traverse Ridge Special Service District needed either to stop charging members The Cove at Little Valley Homeowners Association for services it had never provided or to start plowing snow from private roads in front of homes in the Cove, holding that the district court erred in part.The Service District filed a motion to dismiss for failure to state a claim because the Draper City Code did not require it to service private roads and because the Homeowners Association needed to bring its challenge in a manner dictated by the Utah Tax Code. The Supreme Court affirmed the district court's dismissal of the Cove's first cause of action but reversed its dismissal of the second reversed in part, holding that the district court erred when it concluded that the assessment its members paid to the Service District was a tax as a matter of law. View "Cove at Little Valley Homeowners Ass'n v. Traverse Ridge Special Service District" on Justia Law

Saltz, a plastic surgeon, was sued by a former patient for releasing her photographs to a news outlet. Saltz submitted his legal defense to his malpractice insurance provider, UMIA, which initially defended Saltz but sought a declaratory judgment, claiming that Saltz lacked insurance coverage for the former patient’s claims. The district court found that Saltz was not covered under the plain language of the policy and dismissed his claim for waiver and his request for punitive damages but denied UMIA’s motion for judgment as a matter of law and allowed Saltz’s promissory estoppel and breach of the duty of good faith claims. Over UMIA’s objections, the court also allowed evidence from a settlement negotiation to be presented to the jury, which found in favor of Saltz on both claims.The Utah Supreme Court affirmed in part, reversed in part, and remanded for further proceedings on Saltz’s requests for punitive damages and for attorney fees incurred on appeal. The district court properly allowed Saltz’s claims for promissory estoppel and breach of the duty of good faith to go to the jury; the court was correct to deny UMIA’s motion for a new trial on the claim for breach of the duty of good faith. The court upheld the admission of evidence from the settlement talks. The district court erred in dismissing Saltz’s claims for waiver and for punitive damages. View "UMIA Insurance, Inc. v. Saltz" on Justia Law

After exiting his brother’s truck at a busy intersection, Pierce fatally shot Toala. After receiving his Miranda warnings, Pierce claimed that he acted in self-defense. His statement was later suppressed. There were multiple witnesses, who disagreed about whether Toala was aggressive or threatening toward Pierce. The Utah Supreme Court affirmed Pierce’s conviction for manslaughter by imperfect self-defense as supported by sufficient evidence. The court rejected an argument that the trial court committed plain error by failing to “sua sponte” cut off the prosecution’s questions and comments about the differences between Pierce’s trial testimony and what he told the police. The law concerning any error was not clear at the time of trial. View "State v. Pierce" on Justia Law

The Supreme Court reversed the decision of the Labor Commission Appeals Board dismissing Appellant's interlocutory objection to the appointment of the medical panel assigned to resolve this dispute, holding that the actual bias standard applied by the Board to resolve Appellant's conflict of interest objection did not comport with the statutory requirements.Appellant sought workers' compensation benefits after he injured his back in a work-related accident. The administrative law judge assigned to the case appointed a medical panel to resolve the dispute and appointed Dr. Jeremy Biggs, an occupational medicine physician, to serve as the panel chair. Appellant moved for interlocutory review, arguing that Dr. Biggs should be disqualified because he had a conflict of interest. The Board rejected Appellant's objections and concluded that the accident had not caused permanent injury. The Supreme Court reversed, holding (1) where a medical panelist's impartiality could be reasonably questioned the requirement of an impartial medical evaluation has not been met; and (2) remand was required on this basis. View "Gamez v. Utah Labor Commission" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the conclusion of the district court dismissing Plaintiff's complaint against Washington County School District claiming that the School District had failed to offer it the right of first refusal to repurchase its former property, holding that the court of appeals erred in its interpretation of Utah Code 78-34-20(1)(b), replaced by Utah Code 78B-6-521(1)(a)(ii).Several years after Plaintiff sold a parcel of land to the School District the School District resold the property. Because Utah law requires a government entity to offer property acquired through condemnation or a threat of condemnation to the original owner before disposing of it Plaintiff bought suit, arguing that the School district acquired its property under a threat of condemnation. The district court dismissed the suit for failure to state a claim. The court of appeals affirmed, concluding that a government entity does not specifically authorize the use of eminent domain until it approves an eminent domain lawsuit in an open meeting. The Supreme Court reversed, holding that the statute did not support the appellate court's interpretation of what it means to be specifically authorized. View "Cardiff Wales, LLC v. Washington County School District" on Justia Law

The Supreme Court held in this interlocutory appeal that the district court may not judge the sufficiency of the defendant's showing necessary to overcome a motion to quash based solely on an in camera proffer without first affording the State an opportunity to respond.Defendant was charged with seven felony charges for an alleged pattern of sexual abuse in connection with A.W. over the course of several years while Defendant was A.W.'s pastor. Defendant denied the charges and served A.W. with a subpoena to appear and testify at his preliminary hearing. A.W. moved to quash the subpoena. Defendant moved to make the showing necessary to overcome the motion to quash in camera and only in the district court. The district court granted the motion. The Supreme Court reversed, holding that Defendant must make his proffer under State v. Lopez, 474 P.3d 949 (Utah 2020), in open court, giving the State an opportunity to respond. View "State v. Archibeque" on Justia Law

The Supreme Court affirmed the decision of the district court denying Landowners' motion for summary judgment in their action to quiet title to their property against a homeowners association (HOA), holding that the district court did not err.Landowners purchased properties within the boundaries of the HOA but later discovered that the person who signed and recorded the documents purporting to create the HOA owned a mere 0.4 percent of the territory he sought to include within the boundaries of the HOA, and no other landowners had signed the recorded documents. Landowners, who met resistance in trying to develop their property, brought this action alleging that the HOA and its subsequently amended restrictive covenants were void ab initio. The district court denied Landowners' motion for summary judgment. On appeal, Landowners argued that the covenants must be declared absolutely void under the test set forth in Ockey v. Lehmer, 189 P.3d 51 (Utah 2008). The Supreme Court affirmed, holding that restrictive covenants that are recorded without the signature of the affected landowner are voidable, not absolutely void. View "WDIS, LLC v. Hi-Country Estates Homeowners Ass'n" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant's motion brought under Utah R. Civ. P. 70(b) or, alternatively, as a motion for a misplea, arguing that the prosecution breached the parties' plea agreement, holding that Appellant's constitutional challenge to his guilty plea was properly considered only under the Post-Conviction Remedies Act (PCRA).Appellant was charged with aggravated murder and other counts related to making and transporting a bomb. Pursuant to a plea agreement, Appellant pled guilty to depraved indifference murder. Twenty-three years later, Appellant brought this motion, arguing that there was no other available avenue for relief. The district court dismissed the motion. The Supreme Court affirmed, holding that Appellant's claim should have been brought under the PCRA. View "State v. Thurman" on Justia Law