Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claim for failure to timely file a notice of claim, holding that Plaintiff, a Utah resident injured in Utah by an Arizona municipal employee, may not file a claim against the employee and the municipality after the time to do so has expired under Arizona law but not under Utah law. Plaintiff was involved in a motor vehicle accident in Utah with a driver who was acting in the course and scope of her employment with the City of Flagstaff, Arizona. When Plaintiff filed suit, the City and the driver moved to dismiss arguing that the district court lacked subject matter jurisdiction because Plaintiff did not file her notice of claim within six months as required by Arizona's governmental immunity statute, Ariz. Rev. Stat. 12-821.01. The district court applied the statute as a matter of comity. The Supreme Court affirmed, holding (1) comity was rightfully extended, and the district court correctly applied the statute; and (2) Plaintiff failed to comply with the statute's notice of claim requirement, and therefore, the action was untimely and required dismissal. View "Galindo v. Flagstaff" on Justia Law

In an earlier order explained in this opinion the Supreme Court denied Motorola Solution, Inc.'s Rule 17 motion for stay pending review in this matter involving Utah Communications Authority's (UCA) efforts to hire a private contractor to implement a new statewide emergency public radio system, holding that UCA's motion for a stay was moot. Motorola requested the stay to stop UCA from entering into a contract with Harris Corporation until Motorola's appeal protesting UCA's decision to award that contract for the purpose of implementing the emergency radio system had been resolved. In response, UCA and Harris argued that the motion for a stay was moot because UCAs executive director had already entered into a contract with Harris. Motorola countered that a contract could not be formed until the UCA board had approved it. The Supreme Court denied the motion requesting a stay as moot, holding that the UCA executive director had authority to enter into contracts on UCA's behalf. View "Motorola Solutions, Inc. v. Utah Communications Authority" on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that there was sufficient evidence to sustain the charged aggravator for Defendant's aggravated murder conviction and that the district properly denied Defendant's motion for a new trial, holding that there was no error in the proceedings below. On appeal, Defendant argued that there was insufficient to sustain the determination that he placed another person at "great risk of death" when he killed his victim and that the district court abused its discretion in denying his motion for a new trial. The court of appeals affirmed. The Supreme Court affirmed, holding (1) in determining whether a murder was committed under circumstances in which the defendant caused a "great risk of death" to another person Utah Code 76-5-202(1)(c) is satisfied if the great risk of death was created with a "brief span of time" of the act causing the murder and the acts together "formed a concatenating series of events"; (2) there was a reasonable basis for the jury to conclude that Defendant caused a great risk of death to another in the circumstances of the murder in this case; and (3) the district court did not err in denying Defendant's motion for a new trial. View "State v. Sosa-Hurtado" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court dismissing Plaintiff's claims that Defendant, his employer, fired him in violation of the implied covenant of good faith and fair dealing in his compensation agreement with Defendant, holding that the court of appeals' application of the covenant was improper. In his complaint, Plaintiff claimed that Defendant fired him in an effort to avoid payment of commissions and that, even though he was an at-will employee, his termination violated the implied covenant of good faith and fair dealing. In dismissing the claims, the district court concluded that the covenant could did not apply in this context. The court of appeals reversed, concluding that the covenant can be invoked to prevent employers form using at-will termination to avoid obligations under the compensation agreement. The Supreme Court reversed, holding (1) the covenant of good faith and fair dealing may not be applied to contradict express contractual terms; and (2) the court of appeals' application was inconsistent with the express terms of the compensation agreement and with the parties' course of dealings. View "Vander Veur v. Groove Entertainment Technologies" on Justia Law

In this divorce case, the Supreme Court affirmed the district court's determination that Wife was entitled to alimony but reducing her alimony award in duration and amount because of her extramarital sexual affairs, holding that none of Wife's alleged errors in appeal were an abuse of discretion or plainly incorrect. Specifically, the Court held that the district court (1) properly determined that Wife's infidelities substantially contributed to the end of the marriage; (2) did not abuse its discretion in setting the specific terms of the alimony award; (3) did not err in imputing income to Wife at $1,300 per month; (4) did not err in failing to consider the tax burden of the alimony award; and (5) properly denying Wife's request for attorney fees. View "Gardner v. Gardner" on Justia Law

The Supreme Court answered three questions certified to it by the United States District Court for the District of Utah in this case challenging a civil fine issued under the Political Activities of Public Entities Act, Utah Code 20A-11-1205, answering, inter alia, 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 the statute. Further, the Supreme Court answered (1) the term "ballot proposition" as used in Utah Code 10A-11-1205(1) encompasses the entire referendum process, including the period of time before a referendum's sponsors have obtained the requisite number of signatures on the referendum petition; and (2) the term "ballot proposition" as used in section 10A-11-1205(1) includes the signature gathering phase 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

The Supreme Court reversed the district court's determination that the Metropolitan Water District of Salt Lake & Sandy (Metro) has authority to impose land use restrictions on real property it does not own, holding that Metro's authority over the property did not extend beyond the authority it derived from its easement rights and that the district court's determination regarding the scope of the easement was in error. Metro owned an easement across land owned by the SHCH Alaska Trust. The district court found that Metro's status as a limited purpose local district of the state granted Metro authority beyond what is generally enjoyed by an easement holder to impose restrictions on Alaska's use of the property. The district court also determined that Metro's easement was 200 feet wide, basing the determination on a written description of the easement created by a civil engineer for the Federal Bureau of Reclamation in 1961. The Supreme Court reversed, holding (1) the district court incorrectly interpreted the Limited Purpose Local Districts Act, Utah Code Title 17B, because no provision in the Act authorizes Metro to regulate Alaska's use of its own property; and (2) the court erred in concluding that the civil engineer's written description regarding the easement's scope was dispositive. View "Metropolitan Water District of Salt Lake & Sandy v. SHCH Alaska Trust" on Justia Law

The Supreme Court denied the petition for extraordinary writ sought by advocates for a statewide ballot initiative called the Direct Primary Initiative, holding that Petitioners' statutory claims and all but one of the constitutional claims failed on the merit and that Petitioners failed to carry their burden of identifying an undisputed basis for the relief requested. Petitioners - Count My Vote, Inc., Michael O. Leavitt, and Richard McKeown - were advocates for a proposed initiative that would establish a direct primary election path for placement on the general election ballot for persons seeking a political party's nomination for certain elected offices. The lieutenant governor refused to certify the initiative for the November 2018 ballot, finding that Petitioners failed to satisfy the requirements of Utah Code 20A-7-201(2)(a). Petitioners then brought this petition for extraordinary writ on statutory and constitutional grounds. The Supreme Court denied the petition, holding (1) the majority of Petitioners' statutory and constitutional claims failed on the merits; (2) one of the constitutional claims implicates an underlying dispute of material fact on the nature and extent of any burden on the right to pursue an initiative under Utah Const. art. VI, 1; and (3) Petitioners failed to carry their burden of establishing an undisputed basis for the requested relief. View "Count My Vote, Inc. v. Cox" on Justia Law

In this breach of contract action the Supreme Court affirmed the decision of the court of appeals reversing two of the district court's pretrial evidentiary rulings, holding that the court of appeals did not err in holding that the district court incorrectly excluded expert testimony and other evidence proposed by Plaintiff. Plaintiff, Northgate Village Development, LC, brought this action against the City of Orem seeking to recover the cost of cleaning up property Northgate had purchased from the City. The district court granted summary judgment for the City. The court of appeals reversed. On remand, the City made pretrial motions to exclude some of Northgate's proposed evidence. The district court granted the motion as to Northgate's proposed evidence and excluded Northgate's experts as a discovery sanction. Northgate filed an interlocutory appeal. The court of appeals reversed both evidentiary orders. The Supreme Court affirmed, holding (1) the district court erred in excluding Northgate's proposed expert testimony as a discovery sanction because it applied the wrong version of Utah R. Civ. P. 26; and (2) the district court abused its discretion in excluding the challenged evidence as irrelevant under Utah R. Evid. 401 and as prejudicial under Utah. R. Evid. 403. View "Northgate Village Development, LC v. City of Orem" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming Defendant's conviction of failure to signal for two seconds and failure to obey traffic control devices, holding that the Utah Constitution does not guarantee Defendant a jury trial for his traffic violations. At the time Defendant was charged, the Utah Code classified the offenses as class C misdemeanors. At the arraignment hearing the City amended both charges to infractions, thereby depriving Defendant of a jury trial. Defendant moved to dismiss the information charging him with infractions, arguing that the Utah Constitution guarantees a right to a jury trial in all criminal prosecutions, including those for infractions. The justice court denied Defendant's motion to dismiss and request for a jury trial and convicted Defendant. On appeal, the district court denied Defendant's motion for a jury trial and convicted him of both charges. The Supreme Court affirmed, holding that minor offenses do not trigger the right to a jury trial under article I section 12 of the Utah Constitution. View "South Salt Lake City v. Maese" on Justia Law