Justia Utah Supreme Court Opinion Summaries

Plaintiffs filed a medical malpractice action against Defendant, and the claims brought by one of the plaintiffs were referred to arbitration. After an arbitration panel issued its decision but prior to the district court confirming that ruling and disposing of the remaining claims, Plaintiffs appealed. After the district court’s subsequent ruling, the Supreme Court dismissed as premature Plaintiffs’ appeal. More than sixty days after entry of the judgment, Plaintiffs filed a Utah R. Civ. P. 60(b) motion seeking to reissue the judgment based on the presumption that the district court lacked jurisdiction to enter its previous judgment because it had been divested of jurisdiction by Plaintiffs’ premature notice of appeal. The district court agreed and reissued the judgment, purporting to “amend” the judgment, without substantively altering the original decision. Plaintiffs then filed another notice of appeal. The Supreme Court dismissed the appeal, holding that the district court had jurisdiction to issue the original judgment, and because Plaintiffs failed to timely appeal that judgment, the Supreme Court lacked jurisdiction to address any challenge to the merits. View "Garver v. Rosenberg" on Justia Law

Plaintiff sued Defendant. The district court granted Defendant’s motion for summary judgment in a summary judgment ruling but did not enter an order implementing the summary judgment ruling. Defendant subsequently filed a motion for Utah R. Civ. P. 54(b) certification of final judgment. The district court entered a certification order dismissing Plaintiff’s claims. Operating under the assumption that the two orders were still forthcoming - a Utah R. Civ. p. 7(f)(2) order implementing the court’s summary judgment ruling and a rule 54(b) certifying order - Plaintiff did not file a notice of appeal, instead filing a “motion to proceed with appeal.” The district court denied the motion. Plaintiff stated her intent to appeal the ruling on her motion to proceed with her appeal and the underlying summary judgment ruling. Both parties filed motions for summary disposition. The Supreme Court dismissed the appeal, holding (1) all orders, including interlocutory orders, must satisfy rule 7(f)(2); (2) entry of an order that is rule 7(f)(2) compliant is a prerequisite to rule 54(b) certification; (3) a single order may satisfy both rules 7(f)(2) and 54(b), but to do so it must strictly comply with the requirements of both rules; and (4) the certification order in this case did not meet the requirements of a combined rule 7(f) and rule 54(b) order. View "Butler v. Hon. Thomas L. Kay" on Justia Law

The trustee of the United Effort Plan Trust filed a complaint against the City of Hildale and the Twin City Water Authority (TCWA) (together, Appellants) to compel the subdivision of certain parcels of Trust property located within the City’s boundaries. Because Appellants failed to appear or answer the complaint, the district court entered default judgment against them. Thereafter, Appellants filed a Utah R. Civ. P. 60(b) motion to set aside the judgment. While the motion was pending, Appellants filed a direct appeal from the default judgment. The district court denied Appellants’ Rule 60(b) motion, and Appellants did not appeal the denial. The Supreme Court subsequently dismissed Appellants’ direct appeal from the default judgment, holding that the direct appeal was the incorrect vehicle for relief because it relied exclusively on Rule 60(b) arguments made to the district court in the postjudgment motion and disposed of in the unappealed order. View "Wisan v. City of Hildale" on Justia Law

Energy Claims Limited (ECL), a British Virginia Island company, was the assignee of certain claims of Eneco, Inc. (Eneco), a now defunct Utah corporation. ECL filed suit in Utah district court, asserting Eneco’s claims against Eneco’s former directors, Catalyst Investment Group Limited (Catalyst), Timothy Roberts, and ARM Asset-Backed Securities, S.A. (ARM). All defendants resided, or had their principal place of business, outside of Utah. The district court (1) dismissed ECL’s claims against the former directors, Catalyst, and Roberts on the basis of forum non conveniens; and (2) dismissed the claims against ARM for improper venue based on a forum selection clause. The court of appeals affirmed. The Supreme Court reversed after declining ECL’s invitation to adopt a choice-of-law inquiry as a threshold to its forum non conveniens analysis, holding that the court of appeals erred in affirming dismissal of ECL’s claims against Defendants on the basis of forum non conveniens and on the basis of improper venue. Remanded. View "Energy Claims Ltd. v. Catalyst Inv. Group Ltd." on Justia Law