Justia Utah Supreme Court Opinion Summaries

The underlying dispute in this appeal revolved around the issue of who was contractually obligated to pay workers' compensation benefits to an employee of Employer. The Supreme Court found that Employer's Insurer was required to pay workers' compensation benefits for all of Employer's employees and remanded the case. The district court entered a final judgment. Instead of filing a notice of appeal within thirty days of the district court's judgment, Insurer filed an "objection to judgment." Insurer then filed its notice of appeal within thirty days of the district court's order disposing of that motion. The Supreme Court dismissed the appeal, holding that it lacked jurisdiction to address the appeal as (1) Insurer did not file its notice of appeal within thirty days of the district court's final judgment, and (2) Insurer failed to file a postjudgment motion that would toll the time for appeal or one that the Court had jurisdiction to review. View "Workers Comp. Fund v. Argonaut Ins. Co." on Justia Law

When it was sued by its former president and CEO, the Equine Assisted Growth and Learning Association (EAGALA) requested coverage for the costs of its defense from its insurance carrier, Carolina Casualty. Carolina Casualty denied coverage, contending that the complaint was brought "by, on behalf of, or in the right of" EAGALA, a type of claim excluded from coverage by the insurance policy. EAGALA sued Carolina Casualty to establish coverage for the costs of defending the suit. The district court granted Carolina Casualty's motion for judgment on the pleadings and dismissed EAGALA's complaint after determining that it was unnecessary and improper for the court to consider extrinsic evidence to discern whether Carolina Casualty had a duty to defend EAGALA. The court of appeals reversed, concluding that under the language of the insurance policy, extrinsic evidence was admissible to determined whether the complaint was actually filed by, on behalf of, or in the right of EAGALA. On review, the Supreme Court affirmed the court of appeals' decision, holding that the district court erred when it refused to consider extrinsic evidence as required by the terms of the insurance policy. View "Equine Assisted Growth & Learning Ass'n v. Carolina Casualty Ins. Co." on Justia Law

Sanpete America purchased 110 acres of farmland and water rights from Christian Willardsen pursuant to a land purchase agreement and a warranty deed. After discovering problems with respect to the conveyance of the water right at issue, Sanpete America filed a complaint against Willardsen and Douglas Neeley, Willardsen's attorney, asserting various causes of action and seeking damages. Two successive district court judges issued judgments dismissing Sanpete America's claims against Willardsen and Neeley. On appeal, the Supreme Court affirmed both judges' conclusion that Sanpete America was entitled to no damages and judgment dismissing Sanpete America's claims, holding (1) Willardsen conveyed his portion of the water right to Sanpete America under a warranty deed, (2) Willardsen breached no covenants in the deed, and (3) Neeley's actions were not the cause of Sanpete America's alleged damages. View "Sanpete America, L.L.C. v. Willardsen" on Justia Law

This case concerned the application of payments made in connection with a real estate transaction between Kang Park and Marsha Park and Gary Stanford. The district court granted summary judgment to the Parks, determining, as a matter of law, that none of the payments Stanford submitted to the Parks could be credited toward a personal guaranty Stanford had made on the note payable to the Parks. The court of appeals affirmed the district court's grant of summary judgment, concluding that no evidence indicated the Parks had actual knowledge that Stanford intended for the past payments to apply to his guaranty and no agreement or contractual provision expressly required the Parks to make such an application. On certiorari, the Supreme Court reversed, holding (1) the court of appeals applied the wrong test in its holding, and rather, a rule in which payments are credited toward a personal guaranty when the recipient of the payments has a reasonable basis to know the payments were submitted in satisfaction of the guaranty governed the application of payments toward a personal guaranty; and (2) genuine issues of material fact precluded summary judgment under the rule and the record required further development. Remanded. View "Park v. Stanford" on Justia Law

Barbara and Steven Selvig, as sellers, and Blockbuster Enterprises, as buyer, entered into a real estate purchase contract for the purchase of a bed and breakfast. The contract specified that the deed to the property would be recorded when Blockbuster paid the full purchase price. Before paying the full purchase price, however, Blockbuster recorded the deed. The sellers sued in district court on several theories of liability. The district court granted Blockbuster's motion to dismiss, dismissing (1) the seller's claims for breach of contract and breach of the covenant of good faith and fair dealing, holding that the sellers had elected their remedy pursuant to an election of remedies provision in the contract by keeping the earnest money deposit; and (2) the seller's unjust enrichment claim. The Supreme Court affirmed in part and reversed in part, holding (1) the district court erred in dismissing the seller's contractual claims because the election of remedies provision does not apply to a breach of contract claim out of a wrongful recording of the deed; and (2) the district court correctly dismissed the seller's claim for unjust enrichment because the sale of the property was covered by a written contract. View "Selvig v. Blockbuster Enterprises, L.C." on Justia Law

The Utah Department of Transportation (UDOT) contracted with Meadow Valley Contractors (MVC) for a highway construction project. MVC subcontracted the paving work to Southwest Asphalt Paving. After UDOT refused to allow Southwest to use ribbon paving and assessed MVC a thickness-laying penalty, MVC filed a compliant against UDOT, alleging that (1) it incurred costs not contemplated by the contract as a result of UDOT's prohibition on ribbon paving, and (2) the thickness penalty assessed by UDOT was unwarranted. UDOT denied MVC claims. Southwest then filed a complaint in district court in MVC's name against UDOT alleging breach of contract. The trial court (1) concluded that UDOT breached its contract with MVC by refusing to allow ribbon paving on the construction project, and (2) denied MVC's claim that UDOT had erroneously imposed a paving-thickness penalty. On appeal, the Supreme Court reversed in part and affirmed in part, holding (1) UDOT did did not breach its contract with MVC when it forbade MVC and Southwest from using ribbon paving, and (2) there was sufficient evidence to support the trial court's conclusion that UDOT's interpretation of the contract regarding paving thickness was more reasonable than MVC's interpretation. View "Meadow Valley v. UDOT" on Justia Law

In a 1905 water exchange agreement, Big Ditch Irrigation Company conveyed its Big Cottonwood Creek water right to the Salt Lake City Corporation in exchange for the City's commitment to supply Big Ditch with a specified quantity of irrigation-quality water from City sources. Concerned that Big Ditch was infringing upon the City's water rights, the City initiated this case against Big Ditch and four Big Ditch shareholders in district court. The City sought declaratory judgment on several issues. Big Ditch and the shareholders counterclaimed. The district court granted summary judgment in favor of the City on most major issues. On appeal, the Supreme Court held that the district court properly dismissed the defendants' counterclaims and correctly concluded that the City holds title to the water rights conveyed in the agreement. The Court held, however, that the district court erred in (1) determining that Big Ditch did not have a right to file change applications; (2) determining that the parties had modified the agreement or, alternatively, that Big Ditch was estopped from enforcing its right to the amount of water specified in the agreement; and (3) refusing to dismiss the City's claims against the shareholders. View "Salt Lake City Corp. v. Big Ditch Irrigation Co." on Justia Law