Fundamentalist Church of Jesus Christ of Latter-Day Saints v. Horne

In this case the Supreme Court was asked to answer a certified question about whether the Court's discretionary review of a petition for extraordinary writ and subsequent dismissal on laches grounds is a decision on the merits when it is accompanied by a written opinion, such that later adjudication of the same claim is barred. The question stemmed from litigation surrounding a probate court's reformation and administration of a charitable religious trust. An association of members of the church and beneficiaries of the trust (the FLDSA) filed a complaint in federal court. Later, the FLDSA filed an extraordinary writ petition in state court asserting claims substantially similar to those in the federal case. The federal court stayed its proceedings. The Utah Supreme Court held that the FLDSA's claims were barred on laches grounds and dismissed the petition. When the federal case reached the court of appeals, the court certified to the Supreme Court its question about Utah preclusion law. The Court answered the certified question in the affirmative, holding that a decision like the one reached in state court was a decision "on the merits" for res judicata purposes and would preclude a subsequent action on the same claims between the same parties. View "Fundamentalist Church of Jesus Christ of Latter-Day Saints v. Horne" on Justia Law