Justia Utah Supreme Court Opinion Summaries

An employee working as a manager at a restaurant in Utah slipped on spilled ice in the kitchen and sustained injuries to his shoulder and neck. He had a pre-existing shoulder injury from previous employment but reported new pain and received medical treatment, including surgery. The employee did not notify his employer of the Utah injury within the 180-day deadline specified by state law. He later filed for workers’ compensation benefits, claiming both shoulder and neck injuries resulted from the slip-and-fall.During the initial proceedings before the Utah Labor Commission’s administrative law judge (ALJ), the employer listed lack of timely notice as an affirmative defense but did not specifically seek dismissal on that ground. Instead, the employer argued the lack of a report showed the injury never happened. The ALJ, on her own initiative, dismissed both claims, finding the employee failed to prove timely notice. The Commission’s Commissioner affirmed the dismissal of the shoulder claim based on untimely notice but allowed the neck claim. After further proceedings, the Appeals Board affirmed the ALJ’s decision. Both parties appealed to the Utah Court of Appeals. The court of appeals decided the case entirely on the time-bar issue, finding both claims untimely, and declined to address other challenges.The Supreme Court of the State of Utah reversed, holding that the employer waived the limitations defense by not seeking relief on that ground before the ALJ. The court concluded that the ALJ’s sua sponte ruling on the notice issue did not preserve it for appeal, as it did not satisfy the fairness component of the preservation doctrine. The Supreme Court vacated the court of appeals’ decision and remanded for further proceedings on the remaining merits issues. The court further directed that the shoulder injury claim be remanded to the Labor Commission for consideration of the merits. View "Darden Restaurant v. Labor Commission" on Justia Law

A dispute arose over a 2,300-acre land development project in Washington County, Utah. The owners, Keith and Lorin Walker, planned a large residential community but faced foreclosure following the 2008 financial crisis. To save the project, they entered into a contract with Western Mortgage & Realty Company, which agreed to clear the land’s title and transfer ownership to a jointly controlled entity. Western failed to form the promised entity, leading to litigation. Western sued to quiet title, and the Walkers counterclaimed for breach of contract and fiduciary duty, among other claims.The Fifth District Court held a bench trial, finding in favor of the Walkers on their breach of contract and fiduciary duty claims. The court imposed a constructive trust, awarded the Walkers monetary damages, and granted attorney fees as consequential damages for the breach of fiduciary duty. The Walkers were instructed to seek attorney fees through a post-trial motion under Utah Rule of Civil Procedure 73. After trial, the parties signed a stipulation waiving appeals on prior rulings but reserving the right to appeal any future rulings regarding attorney fees.In their post-trial motion, the Walkers, for the first time, disclosed a hybrid contingency-hourly fee arrangement with their counsel. The district court accepted this late disclosure, finding that it was either for good cause or harmless, and awarded the Walkers consequential damages based on the contingency fee, increasing their monetary award and interest in the trust.On direct appeal, the Supreme Court of the State of Utah reversed the district court’s award of the contingency fee as consequential damages. The court held that attorney fees sought as consequential damages require disclosure under Rule 26, and their foreseeability and amount must be proven at trial. The Walkers’ failure to disclose and prove these elements was neither harmless nor for good cause. The Supreme Court instructed the district court to modify the damages award accordingly. View "Western Mortgage v. Walker" on Justia Law

A man incarcerated at the Utah State Prison killed his cellmate while experiencing a schizophrenic delusion, believing that a voice threatened to kill him and his family if he did not act. The defendant immediately alerted prison staff and explained that he acted to save his own life, without any prior conflict with the victim. He was subsequently charged with murder and sought to invoke a statutory special mitigation defense, arguing that his delusion, if true, would have provided a legal justification for his actions under Utah law.In the Third District Court, Salt Lake County, the defendant filed notice of his intent to seek special mitigation based on his mental state. The State moved to preclude this defense, contending that the defendant’s delusion—compulsion arising from a threat—did not constitute a “legal justification” as intended by the statute, because compulsion is not listed among justification defenses in Utah’s criminal code. The district court disagreed, holding that compulsion could amount to legal justification and allowed the defendant to argue special mitigation at trial. The State then obtained interlocutory review of this ruling.The Supreme Court of the State of Utah reviewed the statutory meaning of “legal justification” in the special mitigation statute. The court held that “legal justification” is a term of art referring only to those defenses recognized as justification at common law and codified in Utah’s justification provisions, not to excuse defenses like compulsion. Because the defendant’s delusional compulsion defense was not included as a justification under the statute, he was ineligible for special mitigation on that basis. The Utah Supreme Court reversed the district court’s ruling and remanded for further proceedings. View "State v. Tamoua" on Justia Law

A special education teacher suffered two separate head injuries at work in 2013 and 2014, resulting in chronic migraines, depression, and other functional limitations. After the second injury, her physician restricted her to light-duty work, but her employer declined to accommodate these restrictions and terminated her employment. The teacher was initially awarded temporary total disability benefits and payment of related medical expenses, but the employer disputed liability for some bills, leading to debt collection efforts against the teacher, which caused her additional stress. She subsequently sued the collection agencies in federal court and received a monetary settlement. After her condition did not improve, the teacher filed a second claim for permanent total disability benefits.The Administrative Law Judge (ALJ) in the Utah Labor Commission held hearings, appointed a medical panel to distinguish the effects of the work injuries from non-work-related stressors, and ultimately awarded permanent total disability benefits, as well as past and future medical expenses. The ALJ denied the employer’s attempt to reopen the evidentiary record to introduce evidence related to the debt collection actions and a later car accident, and also denied the employer’s claim for a subrogation offset from the teacher’s federal lawsuit settlement. The Utah Labor Commission affirmed the ALJ’s findings and award.The Supreme Court of the State of Utah reviewed the case on certification from the court of appeals. The court held that the medical panel was properly instructed and its findings were supported by substantial evidence, the ALJ did not abuse its discretion by refusing to reopen the evidentiary record, and the Commission’s award of permanent total disability benefits was supported by the evidence. The court also held that the employer was not entitled to a subrogation offset, as the settlement from the federal lawsuit did not compensate for the work injuries. The Supreme Court declined to disturb the Commission’s order. View "Granite School District v. Labor Comm." on Justia Law

This case involves two children who were removed from their parents’ custody in 2015 due to neglect and abuse but were returned after their parents participated in services. In 2019, the State again removed the children following similar findings of neglect, unsanitary conditions, and developmental delays. Mother left the country for a year, leaving the children with father, who also failed to provide appropriate care. The children were placed with foster parents in Tennessee who wished to adopt them. After reunification efforts failed, the State filed a petition to terminate both parents’ rights. Mother only began accessing services after the petition was filed.The Fourth District Juvenile Court held a first trial in 2021 and terminated Mother’s parental rights, but the court’s order failed to adequately explain alternatives to termination. Mother’s initial appeal to the Utah Court of Appeals was dismissed as untimely. She then sought relief in juvenile court, which re-entered the order, allowing her to appeal again. The parties later stipulated that the juvenile court’s best interest findings were insufficient, and the Court of Appeals reversed and remanded for further analysis. A second trial was held, and the juvenile court issued a new order in December 2023, again terminating Mother’s parental rights, finding neglect, parental unfitness, and that termination was strictly necessary for the children’s welfare.On appeal, the Supreme Court of the State of Utah addressed jurisdictional questions arising from the untimely appeal and prior proceedings. The court held that it had appellate jurisdiction over Mother’s challenge to the juvenile court’s post-remand December 17, 2023 order, but lacked jurisdiction over alleged errors predating the first appeal. The court affirmed the juvenile court’s determination that termination was strictly necessary to promote the children’s best interest and rejected Mother’s claims that the decision lacked evidentiary support. View "In re J.A.C." on Justia Law

A man was cited and charged in the Salt Lake City Justice Court after allegedly causing a car accident while driving under the influence of alcohol. The charges included a class B misdemeanor for DUI, as well as other related offenses. Several months after the charges were filed, the defendant attempted to plead guilty, but the City refused to consent, invoking a state law requiring prosecutorial approval for guilty pleas in DUI cases. The justice court declined to accept his plea without the City’s consent.The defendant then moved the justice court to declare the prosecutorial consent law unconstitutional, arguing it violated Utah’s separation of powers doctrine and his due process rights. While this motion was pending, the Salt Lake County District Attorney filed enhanced, felony-level charges against him in the district court. The City moved to dismiss the justice court case without prejudice, and the justice court denied the defendant’s constitutional challenge, finding no violation of the separation of powers and concluding the due process argument was inadequately briefed. The case in the justice court was dismissed without prejudice.The Supreme Court of the State of Utah reviewed the defendant’s petition for extraordinary relief. The court found that the defendant had properly invoked its authority for relief under Utah Rule of Appellate Procedure 19 regarding the separation of powers claim, since no direct appeal was available. However, the court declined to reach the merits or grant relief, holding that the defendant had not shown he was likely to benefit from a favorable ruling because felony charges were already pending in district court and it was speculative that the justice court would accept his guilty plea. The court also rejected the due process challenge, finding the defendant had not addressed the justice court’s basis for rejection. The petition for extraordinary relief was denied. View "Adams v. Hon. Robison" on Justia Law

The appellant was convicted by a jury of multiple child sexual abuse offenses. After his convictions were affirmed on direct appeal by the Utah Court of Appeals, and after the Utah Supreme Court denied certiorari, he filed a petition for post-conviction relief in the Fourth District Court. His initial petition raised claims that had already been addressed on direct appeal, leading the district court to dismiss it as procedurally barred. Subsequently, new counsel moved to set aside the dismissal, arguing he had been deprived of notice and a hearing. The district court granted the motion and reinstated the petition. The appellant then sought and received leave to amend his petition, but the amended version included new claims and was filed after the one-year statute of limitations imposed by the Post-Conviction Remedies Act (PCRA).The State moved to dismiss the amended petition as untimely, contending that the new claims did not relate back to the original petition under Utah Rule of Civil Procedure 15(c). The district court agreed, finding that the new claims were entirely different from the original claims and did not satisfy the relation-back requirements. The court rejected the appellant’s argument that Utah Rule of Civil Procedure 65C(h)(3) independently allowed the amendment regardless of timeliness, and also dismissed his assertions that the application of Rule 15(c) was discretionary or that the PCRA’s time bar was unconstitutional. The appellant timely appealed; the case was briefly transferred to the Utah Court of Appeals before being recalled by the Supreme Court of Utah.The Supreme Court of Utah affirmed the district court’s dismissal. The court held that Rule 15(c) applies to post-conviction petitions and that Rule 65C(h)(3) does not override the relation-back requirement. It clarified that neither its precedent nor the Utah Constitution invalidates the PCRA’s one-year time bar or requires an “interests of justice” exception. Accordingly, the dismissal of the amended petition as untimely was upheld. View "Nunez v. State" on Justia Law

A man was accused of sexually abusing and raping his niece when she was a child. The alleged abuse occurred over several years, beginning when the niece was approximately nine or ten years old and continuing until she was about twelve. The niece did not disclose the abuse at the time, but years later, after becoming an adult, she reported the incidents to law enforcement. The prosecution relied heavily on her testimony, as well as testimony from an expert witness who described general patterns in child sexual abuse disclosures, and evidence regarding text messages sent by the accused to the niece.At trial in the Third District Court, a jury convicted the defendant on four counts of aggravated sexual abuse of a child and one count of rape of a child. The defense raised several objections and arguments, including challenges to the admissibility of the expert witness testimony under Utah Rule of Evidence 702, claims of ineffective assistance of counsel for not objecting to the use of the term "victim" at trial, and assertions that the niece’s testimony was inherently improbable and therefore insufficient to support a conviction. The trial court denied a motion for directed verdict and allowed the challenged evidence and arguments over defense objections.The Supreme Court of the State of Utah reviewed the case on direct appeal. The court held that the defendant had waived much of his challenge to the expert testimony by abandoning those arguments in the trial court, and he failed to establish that his counsel was ineffective in handling the expert’s statements or the use of the word “victim.” The court also found that counsel’s decision not to object to testimony about the niece’s self-harm or to raise a challenge based on inherent improbability did not constitute deficient performance. The court affirmed the convictions, finding no reversible error or cumulative prejudice. View "State v. Castillo" on Justia Law

Two children were born to their biological parents in 2013 and 2014. The parents’ relationship was unstable and marked by frequent separations, substance abuse, and incidents of violence and neglect that placed the children in danger. Over the years, the children experienced episodes of direct harm, including exposure to controlled substances and physical endangerment. After a series of disruptive events involving both parents, the children were placed in the full-time care of their maternal grandparents in July 2020, following interventions by child protective services. Since that time, the parents have had little or no meaningful contact with the children, and the grandparents have provided a stable, nurturing environment.After the grandparents petitioned to adopt the children and terminate the parents’ rights, the Eighth District Court conducted a bench trial. The court made detailed factual findings about the parents’ ongoing substance abuse, instability, and inability to protect or care for the children. It concluded that statutory grounds for termination were met, including abandonment, neglect, unfitness, and token efforts to avoid harm. The district court further found that termination was in the children’s best interests and granted the adoption, but did not expressly determine whether termination was “strictly necessary” to promote the children’s best interests or consider alternatives short of termination.The Supreme Court of the State of Utah reviewed the case on certification from the Court of Appeals. The court held that, under Utah law, a court must find that termination of parental rights under the Adoption Act is “strictly necessary” to promote the child’s best interest, incorporating this requirement from the Termination and Restoration of Parental Rights Act. However, the Supreme Court found that the district court’s failure to make a specific strictly necessary finding was harmless error, given the unchallenged factual findings that no feasible alternative short of termination could protect the children. The decision of the district court was affirmed. View "Ross v. Kracht" on Justia Law

After a father was incarcerated for sexual abuse of a minor in 2013, his contact with his four children became sporadic, limited mostly to phone calls and occasional cards or gifts. The children, three of whom have special needs, lived with their mother, who moved back to Utah and eventually divorced the father. She later remarried, and her new husband became a father figure to the children. In 2020, the mother and stepfather sought to adopt the children, amending their petition to also request the termination of the biological father’s parental rights.The Second District Court in Weber County held a two-day hearing, considering testimony from family members and experts regarding the children’s needs and the impact of potential disruption to their stability. The district court found clear and convincing evidence for four grounds of termination: abandonment, neglect, unfitness, and token efforts. It further determined that termination was strictly necessary to promote the children’s best interest, especially given their susceptibility to instability due to special needs. The court rejected alternatives such as continuing the status quo or establishing guardianship, finding these would risk future litigation and undermine stability.The Utah Supreme Court, reviewing the case on certification from the Court of Appeals, applied a deferential standard and focused solely on whether the district court’s determination that termination was strictly necessary was against the clear weight of the evidence. The Supreme Court concluded that the district court had properly conducted a particularized analysis of the children’s needs, rejected speculative or categorical concerns, and relied on evidence regarding the likely disruption from the father’s reentry. The Supreme Court affirmed the district court’s decision, holding that the termination of parental rights under the Utah Adoption Act must be strictly necessary to promote the child’s best interest, and that this standard was met in the present case. View "In re Adoption of B.C." on Justia Law