Justia Utah Supreme Court Opinion Summaries

A group of landowners in Summit County, Utah, challenged a proposed ballot measure to incorporate a new municipality called West Hills. The sponsor of the incorporation, Derek Anderson, had modified the proposed boundaries after the statutory deadline for landowners to request exclusion from the new municipality had passed. As a result, certain landowners whose properties were added late were unable to seek exclusion, even though similarly situated landowners had previously been allowed to do so.The landowners filed suit in the Third District Court, Silver Summit, arguing that the Municipal Incorporation Code, as applied, violated the Uniform Operation of Laws Clause of the Utah Constitution. The district court granted summary judgment for the landowners, finding the code unconstitutional as applied and invalidating the certification of the West Hills ballot measure. The court determined that the plaintiffs were “specified landowners” who would have been entitled to exclusion if their properties had been added earlier, and that the legislature’s interest in certainty did not justify the disparate treatment.The sponsor then filed an emergency petition for extraordinary relief with the Supreme Court of the State of Utah, seeking to overturn the district court’s order before the upcoming election. The Utah Supreme Court, after expedited briefing and oral argument, denied the petition for extraordinary relief. The court held that, under the unique circumstances, it would not exercise its discretion to issue a writ due to the potential disruption and confusion in the election process, including the risk of voter suppression and interference with electioneering efforts. The denial was without prejudice to the sponsor’s ability to pursue an appeal or interlocutory review of the district court’s order. View "Anderson v. Bates" on Justia Law

In this case, Utah voters passed Proposition 4 in 2018, a citizen initiative designed to reform the state’s redistricting process and address partisan gerrymandering. Before the next redistricting cycle, the Utah Legislature repealed Proposition 4 and replaced it with Senate Bill 200 (S.B. 200), which eliminated the key reforms established by the initiative. Several organizations and individuals challenged this legislative action, arguing that the repeal violated Utahns’ constitutional right to alter or reform their government through the initiative process.The Third District Court initially dismissed the plaintiffs’ claim that the Legislature’s repeal of Proposition 4 was unconstitutional. On interlocutory appeal, the Supreme Court of Utah held that the people’s right to reform their government via initiative is constitutionally protected and remanded the case for further proceedings. On remand, the district court granted summary judgment to the plaintiffs, finding that S.B. 200 unconstitutionally impaired the reforms enacted by Proposition 4 and was not narrowly tailored to serve a compelling state interest. The court declared Proposition 4 to be the law, enjoined the use of the 2021 Congressional Map enacted under S.B. 200, and established a remedial process for creating a compliant map. The Legislature’s request to stay the injunction on the 2021 map during the remedial process and any appeals was denied by the district court.The Supreme Court of the State of Utah reviewed the Legislature’s emergency petition for extraordinary relief, which challenged only the district court’s denial of the stay. The Supreme Court held that the Legislature had not shown the district court abused its discretion in denying the stay, as their arguments focused on the remedial process rather than the legal standard for granting a stay. The petition for extraordinary relief was therefore denied. View "State Legislature v. League of Women Voters" on Justia Law

The case involves a dispute over a proposed constitutional amendment in Utah, referred to as Amendment D. The amendment, proposed by the Utah State Legislature, seeks to change the state constitution in three significant ways: specifying that the right to alter or reform the government can only be exercised through constitutional processes, banning foreign influence in the initiative and referendum processes, and granting the Legislature unlimited power to amend or repeal any law passed by a citizen initiative. The controversy centers on whether the amendment was properly submitted to voters and whether it was published as required by the Utah Constitution.The Third Judicial District Court in Salt Lake County reviewed the case and found that the Legislature had not complied with the constitutional requirements for submitting and publishing the proposed amendment. The court ruled that the ballot title for Amendment D was misleading and did not accurately reflect the substance of the amendment, thus failing to meet the Submission Clause of the Utah Constitution. Additionally, the court found that the Legislature did not cause the amendment to be published in newspapers across the state for two months preceding the election, as required by the Publication Clause. Consequently, the district court issued a preliminary injunction declaring Amendment D void and ordered that any votes cast on the amendment not be counted.The Utah Supreme Court reviewed the district court's decision and affirmed the preliminary injunction. The Supreme Court agreed that the ballot title was misleading and did not provide voters with a clear understanding of what they were voting for or against, thus violating the Submission Clause. The Court also held that the Legislature failed to comply with the Publication Clause by not ensuring continuous publication of the amendment's text in newspapers for the required two-month period. The Supreme Court concluded that the district court did not abuse its discretion in finding that the balance of harms and the public interest favored issuing the preliminary injunction. As a result, Amendment D was declared void, and any votes cast on it will have no effect. View "League of Women Voters v. Utah State Legislature" on Justia Law

Phil Lyman sought extraordinary relief from the Utah Supreme Court regarding the 2024 primary election for the Utah Republican Party. He requested the court annul the primary election results and certify him as the Republican nominee for Governor in the general election. Lyman argued that the Republican Party’s internal rules should override Utah’s election laws, a claim previously rejected by the court in Utah Republican Party v. Cox. Additionally, Lyman sought the production of voter signatures from nominating petitions and the removal of Lieutenant Governor Deidre Henderson and Governor Spencer Cox from office for alleged malfeasance.The lower courts had not reviewed this case. Lyman filed his petition directly with the Utah Supreme Court, bypassing the district court. He argued that it was impractical to file in the district court due to the urgency of the impending general election deadlines and the long-standing issues surrounding Senate Bill 54, which had been litigated in various courts.The Utah Supreme Court denied Lyman’s petition. The court held that the Republican Party’s internal rules do not override state election laws, reaffirming its decision in Utah Republican Party v. Cox. The court also found that Lyman had not demonstrated why it was impractical to seek relief in the district court and noted that he could not assert claims on behalf of other candidates. Additionally, the court determined that Lyman had not exhausted his administrative remedies under the Government Records Access and Management Act (GRAMA) for his request for voter signatures. Finally, the court found no viable factual or legal basis for Lyman’s request to remove Henderson and Cox from office. Consequently, the court denied Lyman’s petition for extraordinary relief and his related injunction motions as moot. View "Lyman v. Cox" on Justia Law

Colby Jenkins contested the results of the 2024 primary election for the Utah Republican Party candidate for the U.S. House of Representatives in Utah’s Second Congressional District. After a recount, election officials determined that Celeste Maloy had won by a narrow margin. Jenkins challenged the rejection of certain ballots that were deemed untimely because they were not postmarked by the deadline specified in Utah’s election code. He argued that these ballots were mailed before election day but were delayed in receiving a postmark due to variations in U.S. Postal Service practices.The Lieutenant Governor questioned whether Jenkins had the standing to assert constitutional arguments on behalf of the voters whose ballots were not counted. However, the court did not need to decide on this issue because Jenkins failed to establish that he was entitled to the relief he sought. Jenkins argued that the statutory postmark requirement resulted in unequal treatment of voters and interfered with the fundamental right to vote. However, he did not adequately brief these constitutional arguments, failing to cite relevant case law or provide sufficient analysis.The Utah Supreme Court denied Jenkins’s petition for extraordinary relief. The court held that Jenkins did not meet his burden of demonstrating a constitutional violation. Specifically, Jenkins did not show that election officials failed to comply with any statutory mandate, nor did he provide adequate legal support for his claims that the postmark requirement was unconstitutional. The court concluded that voters could ensure their ballots were timely postmarked by mailing them well in advance or by taking them directly to the post office. Therefore, the petition was denied. View "Jenkins v. Beaver County" on Justia Law

The case involves a dispute over the Utah Legislature's repeal and replacement of a citizen initiative known as "Proposition 4," which aimed to reform the state's redistricting process to prevent partisan gerrymandering. Proposition 4, passed by Utah voters in 2018, established an Independent Redistricting Commission and set forth neutral redistricting standards, including a prohibition on partisan gerrymandering. However, before the next redistricting cycle, the Utah Legislature enacted Senate Bill 200 (S.B. 200), which repealed Proposition 4 and replaced it with a new law that did not include the same anti-gerrymandering provisions and weakened the role of the Independent Commission.In the Third Judicial District Court, Salt Lake County, the plaintiffs argued that the Legislature's actions violated the Utah Constitution by nullifying the reforms enacted by the people through Proposition 4. The district court dismissed this claim, holding that the Legislature has the authority to amend or repeal any statute, including those enacted by citizen initiative, without limitation. The plaintiffs appealed this decision.The Utah Supreme Court reviewed the case and focused on two constitutional provisions: the Initiative Provision in article VI, section 1, which grants the people the power to initiate legislation, and the Alter or Reform Clause in article I, section 2, which states that the people have the right to alter or reform their government. The court concluded that these provisions, when read together, limit the Legislature's power to amend or repeal a citizen initiative that reforms the government. The court held that the people’s right to reform the government through an initiative is constitutionally protected from legislative actions that would impair the reform enacted by the people.The Utah Supreme Court reversed the district court's dismissal of Count V, which challenged the Legislature's repeal and replacement of Proposition 4, and remanded the case for further proceedings. The court emphasized that legislative changes to a government-reform initiative must not impair the reform and must be narrowly tailored to advance a compelling government interest if they do. View "League of Women Voters v. Utah State Legislature" on Justia Law

A group of Utah voters, led by Ian Daniel Phillips, sought to initiate state legislation that would impose an age limit on Utah candidates for federal office. The Lieutenant Governor of Utah rejected the group's initiative application, concluding that the proposed law was "patently unconstitutional" under U.S. Term Limits, Inc. v. Thornton, a Supreme Court case that forbids states from enacting laws imposing qualifications on candidates for federal congressional office. The group then sued the Lieutenant Governor, seeking a declaration that the initiative is not patently unconstitutional and could become law if enacted.The district court dismissed the group's complaint, ruling that the proposed initiative is "squarely foreclosed by" Thornton, a decision that the court had no authority to overrule. The group appealed, maintaining that Thornton should be overruled because its prohibition on state-created qualifications for federal officeholders violates the Tenth Amendment of the United States Constitution. However, they acknowledged that the Supreme Court of the State of Utah lacks authority to overturn Thornton and asked the court to affirm the district court’s decision, thereby paving the way for them to petition the United States Supreme Court for review.The Supreme Court of the State of Utah affirmed the district court's ruling. The court held that the group had appellate standing, despite their concession that they cannot prevail at this stage of the appeal. The court also agreed with the district court that the proposed law is patently unconstitutional under Thornton. Therefore, the group did not state a claim upon which relief may be granted. View "Phillips v. Henderson" on Justia Law

The Supreme Court denied a motion for emergency relief and a petition for extraordinary writ in this election dispute, holding that the motion and petition failed to demonstrate that the relief Petitioners sought was timely requested and available.Petitioners filed a motion for emergency relief and an extraordinary writ seeking an order compelling the Lieutenant Governor to remove Joel Ferry's name from the ballot for the November 2022 general election. The Supreme Court denied both the motion and the petition, holding that the documentation accompanying the petition and motion strongly suggested that there would be inadequate time to alter the ballots before the mailing deadline even if the court ruled immediately. View "Utah Democratic Party v. Henderson" on Justia Law

The Supreme Court dismissed in part Plaintiff's appeal from the decision of the district court declining to overturn the results of the election for the office of San Juan County Commissioner, holding that Plaintiff lacked standing to file suit.In 2018, Defendant declared that he would run for the office of San Juan County Commissioner. To prove he was a county resident and therefore eligible to run for county offense, Defendant provided coordinates and satellite images for his San Juan County residence. After Defendant won the election, Plaintiff, who was also running for county commissioner, brought this lawsuit arguing that Defendant did not live at the coordinates he provided with his declaration of candidacy. The district court declined to overturn the results of the election. The Supreme Court affirmed, holding (1) Plaintiff lacked standing to file suit because he failed to allege a sufficiently particularized injury; and (2) the district court properly rejected Defendant's cross-appeal for attorney fees. View "Laws v. Grayeyes" on Justia Law

The Supreme Court reversed the judgment of the district court ruling that it lacked jurisdiction over this challenge to the rejection of a referendum application, holding that the district court erred in its interpretation of Utah Code 20A-7-602.8(4)(a) and its conclusion that it lacked jurisdiction.Appellants, residents and registered voters of Morgan County, filed an application to submit an ordinance approving the development of a ski resort community to a referendum. The county clerk rejected the referendum application. Appellants then filed in the district court a petition challenging the rejection of the proposed referendum. The district court dismissed the challenge for lack of jurisdiction based on its reading of section 20A-7-602.8(4)(a). The Supreme Court reversed, holding (1) sponsors are prohibited from pursuing an extraordinary writ in the Supreme Court under section 602.8(4)(a) when they cannot satisfy the requirements of Utah R. App. P. 19; and (2) Appellants in this case appropriately raised their challenge in the district court. View "Croft v. Morgan County" on Justia Law