Justia Utah Supreme Court Opinion Summaries

This debt collection action arose from a credit agreement between U.S. Bank and Charles Migliore. Livingston Financial, LLC, as assignee for U.S. Bank, brought suit against Migliore for breach of the credit agreement. The Supreme Court granted summary judgment for Livingston. Approximately two years after the district court denied Migliore’s motion to reconsider summary judgment pursuant to Utah R. Civ. P. 60(b), Migliore filed a renewed Rule 60(b) motion to set aside the judgment. The district court denied the renewed motion and granted Livingston’s motion for attorney fees. Migliore appealed the original grant of summary judgment, the denial of the renewed Rule 60(b) motion, and the order granting attorney fees. The court of appeals (1) dismissed the appeal of the original summary judgment order and the order denying the renewed rule 60(b) motion on the basis that it lacked jurisdiction; and (2) affirmed Livingston’s award of fees. The Supreme Court affirmed, holding that the court of apepals (1) erred when it concluded that it lacked jurisdiction to review the district court’s denial of Migliore’s renewed Rule 60(b) motion, but the renewed motion was improper and without merit; and (2) correctly affirmed the award of attorney fees. View "Migliore v. Livingston Fin. LLC" on Justia Law

After Plaintiff was terminated from his employment with NCR Corporation, Plaintiff brought suit, alleging thirteen causes of action. The district court dismissed eleven of Plaintiff’s claims pursuant to Utah R. Civ. P. 12(b)(6). The district court subsequently granted summary judgment to Defendant on Plaintiff’s remaining two claims for wrongful discharge in breach of an employment contract and breach of the implied covenant of good faith and fair dealing. Specifically, the court concluded that Plaintiff had failed to present evidence of an employment contract between the parties sufficient to overcome the presumption of at-will employment under Utah law. The court of appeals reversed the district court’s grant of summary judgment, concluding that NCR’s corporate policy manual could be read to create an implied contract rebutting the presumption that Plaintiff was an at-will employee. The Supreme Court reversed, holding that the court of appeals erred in determining that the language contained in NCR’s policy manual evidenced an intent to form an implied-in-fact contract sufficient to overcome the presumption of at-will employment. View "Tomlinson v. NCR Corp." on Justia Law

This case stemmed from the district court’s approval of the Utah Department of Financial Institutions’ (UDFI) seizure of America West Bank Members, L.C. (Bank) and the appointment of the Federal Deposit Insurance Corporation as receiver of the Bank. The Bank filed a complaint against the State, UDFI, and the director of UDFI (collectively, the State), alleging breach of contract, breach of the covenant of good faith and fair dealing, constitutional takings, and due process violations. The district court dismissed the Bank’s claims for lack of sufficient factual allegations under Utah R. Civ. P. 12(b)(6). The Supreme Court affirmed, holding (1) the district court did not err when it dismissed the Bank’s claims; and (2) the district court did not hold the Bank to a heightened pleading standard. View "America West Bank Members, L.C. v. State" on Justia Law

James Garside acquired shares in South Despain Ditch Company in contravention of corporate restrictions on transferability of South Despain shares. After the sale, South Despain refused to issue certificates in Garside’s name and recognize him as a shareholder, claiming that the sale violated the transfer restrictions and was therefore was void. Garside filed suit, challenging the enforceability of the restrictions and asserting that their enforcement put South Despain in breach of its obligations in contract, fiduciary duty and the Utah Nonprofit Corporation Act. The district court granted summary judgment in favor of South Despain. Garside died during litigation, and Paul Southam proceeded on appeal. The Supreme Court affirmed, holding that the restrictions on the transfer of South Despain shares were enforceable, and thus, Southam acquired no viable rights as a shareholder. Absent a shareholder interest in the corporation, Southam lacked standing to pursue any of his claims. View "Southam v. S. Despain Ditch Co." on Justia Law

Appellant and her two siblings owned certain parcels of land in Park City as tenants in common with United Park City Mines (UPCM). Appellant and UPCM decided jointly to develop the parcels, and Wasatch County approved the parties’ development plan. UPCM was subsequently acquired by Mountain Resort Developments’ (MRD) parent company. MRD and Appellant could not agree how to jointly develop the property or on a purchase price for Appellant’s interest in the parcels. The parties ultimately entered a settlement agreement and exchanged interests in the parcels. After the exchange of deeds under the settlement agreement, MRD asserted that Appellant had not retained development rights under the development plan. Appellant sued for breach of contract, among other claims. The district court granted summary judgment for MRD on all of Appellant’s claims. The Supreme Court affirmed, holding (1) Appellant’s breach of contract claim failed because Appellant and MRD did not agree to continue to develop their properties in compliance with the development plan, and therefore, there was no reasonable basis for Appellant to believe she would retain development rights as detailed in that plan; and (2) the remainder of Appellant’s claims failed because Appellant did not allege facts sufficient to satisfy the elements of those causes of action. View "Keith v. Mountain Resorts Dev., LLC " on Justia Law

While employed with Employer, Employee agreed to arbitrate any disputes arising from his employment. Employee's employment was later terminated. Employee filed a charge of discrimination with the Utah Anti-Discrimination and Labor Division of the Utah Labor Commission (UALD), alleging that Employer discriminated against him, retaliated against him, and harassed him. The UALD dismissed Employee's discrimination claims. Employee appealed to the Utah Labor Commission. The district court subsequently granted Employer's motion to compel arbitration and ordered Employee to submit to arbitration. The Supreme Court vacated the order compelling arbitration, holding that the district court erred in compelling arbitration because the plain language of the arbitration clause in Employee's employment contract allowed him to pursue administrative remedies prior to submitting to arbitration.View "Zions Mgmt. Servs. v. Record" on Justia Law

Appellant entered into a contingency fee agreement with Appellee, an attorney, which provided that Appellee was entitled to one-third of Appellant's primary award. The underlying action resulted in a judgment in favor of Appellant. Thereafter, the district court awarded a supplemental attorney fees award to Appellant. Appellant paid Appellee one-third of he primary judgment but did not pay Appellee any portion of the supplemental attorney fees award. After Appellant did not give Appellee one-third of the attorney fees award, Appellee filed an attorney's lien against his asserted one-third share. The district court denied Appellee's lien. Appellee subsequently filed an seeking a declaration that he was entitled to one-third of Appellant's attorney fees award. The district court entered judgment in favor of Appellee. The Supreme Court affirmed, holding (1) the agreement was unambiguous; and (2) under the agreement's terms, Appellee was entitled to one-third of both the primary judgment and the court-awarded attorney fees.View "Redd v. Hill" on Justia Law

Legacy Resources, Inc. brought several claims against Liberty Pioneer Energy Source, Inc. The district court dismissed Legacy's breach of contract and trade secret claims on summary judgment, determining (1) Legacy violated the securities laws by acting as an unlicensed broker in recruiting investors on behalf of Liberty; and (2) Legacy's securities violations rendered its contract unenforceable under Utah Code 61-1-22(8). The Supreme Court affirmed in part and reversed in part, holding (1) the undisputed facts sustained the conclusion that Legacy acted as an unlicensed broker, which violation foreclosed the enforcement of one of its contracts; but (2) another of Legacy's contracts was not implicated by the securities violation, and thus the district court erred by granting summary judgment on Legacy's claim under that contract, along with its trade secret claim. View "Legacy Res., Inc. v. Liberty Pioneer Energy Source, Inc." on Justia Law

In 2002, Plaintiff, the owner of a car dealership, executed two vehicle contracts with Henry Day Ford to preorder two Ford GT40s (later renamed the GT). After Henry Day learned it would not be receiving GT40s in its allocation, it refunded Plaintiff's deposit. Plaintiff did not object. In 2004 and 2005, Henry Day learned it had been allocated three GTs. Plaintiff demanded that Henry Day sell him two GTs at the price specified under the contracts. Henry Day instead offered to sell Plaintiff one GT for a higher price. Plaintiff refused the offer and filed a complaint alleging breach of contract and unjust enrichment. The district court ruled in favor of Henry Day. The court of appeals reversed, holding (1) despite a latent ambiguity in the contracts regarding the identity of the vehicles to be sold, both parties intended that the contracts cover the vehicle now known as the Ford GT; and (2) Plaintiff did not intend to abandon the vehicle contracts. The Supreme Court affirmed, holding (1) the vehicle contracts contained a latent ambiguity, but the ambiguity did not excuse either party's performance under the contracts; and (2) the issue of whether Plaintiff abandoned his rights under the contracts required a remand for additional findings. Remanded.View "Watkins v. Henry Day Ford" on Justia Law

The Central Utah Water Conservancy District (CUWCD) entered into an agreement with three canal companies to improve irrigation structures belonging to the canal companies in exchange for rights to the increased water flow arising from the improvements. CUWCD failed to complete its obligations under the agreement and filed a declaratory action to establish its contractual rights. The district court determined that because CUWCD breached its obligations under the agreement, two of the canal companies were entitled to enforce the bargained-for damages provisions, which resulted in CUWCD's losing its prospective water rights. The Supreme Court affirmed, holding that CUWCD's breach was material, and the breach was not excused by the doctrine of impracticability or CUWCD's tender of cash in lieu of performance. View "Cent. Utah Water Conservancy Dist. v. Upper East Union Irrigation Co." on Justia Law