Justia Utah Supreme Court Opinion Summaries

Randi Mariani crashed her motor scooter and sustained a serious injury during a driving skills test, which she was taking to obtain a motorcycle endorsement to her driver license. Following the crash, the Utah Department of Public Safety-Driver License Division (DLD) denied Mariani’s application for the endorsement. Mariani sued the DLD for negligently causing her injury. The district court granted summary judgment to the DLD based on governmental immunity, and the court of appeals affirmed.The district court concluded that the DLD was immune from Mariani’s suit under the Governmental Immunity Act of Utah (GIA), reasoning that Mariani’s injury arose out of the administration of her motorcycle skills test, which was part of the licensing process. The court of appeals agreed, stating that Mariani’s injury was at least incident to the licensing approval process.The Utah Supreme Court reviewed the case to determine whether the court of appeals erred in affirming the district court’s decision. The Supreme Court focused on the specific language of the GIA’s licensing exception, which provides immunity for injuries that arise out of or in connection with the denial of a license. The Court concluded that the relevant conduct was the denial of the motorcycle endorsement, not the licensing process itself. The Court further determined that there was no causal relationship between the denial of the license and Mariani’s injury, as the injury occurred before the denial. Therefore, the licensing exception did not apply, and the DLD was not immune from Mariani’s suit. The Supreme Court reversed the court of appeals’ decision and remanded the case for further proceedings. View "Mariani v. Driver License Division" on Justia Law

In 2020, Utah law temporarily allowed municipalities to annex unincorporated areas without a petition or county consent. During this period, the Town of Hideout annexed land in Summit County. After receiving a certificate of annexation from the Lieutenant Governor, Summit County challenged the annexation and the related municipal ordinance in district court, claiming procedural violations and seeking to invalidate the annexation.The Fourth Judicial District Court in Wasatch County ruled in favor of Summit County, granting summary judgment on the grounds that Summit County had standing to challenge the annexation and that the annexation ordinance was invalid due to procedural issues. The court found that Summit County had standing under various statutes and the doctrine of public interest standing.The Utah Supreme Court reviewed the case and reversed the district court's decision. The Supreme Court held that Summit County lacked a legally protectible interest under the relevant statutory scheme, which did not provide counties with a right to challenge annexations. The court also determined that the public interest standing doctrine could not compensate for this lack of a legally protectible interest because the legislature had explicitly excluded counties from the annexation process. Consequently, the Supreme Court directed the district court to dismiss the case. View "Hideout v. Summit County" 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

Linzi Labrum, the petitioner, sought a waiver of rules 14-704(c)(2) and 14-704(c)(3) of the Utah Supreme Court Rules of Professional Practice. These rules require graduates of non-ABA-accredited law schools to practice law in another state for ten years before becoming eligible to take the Utah bar exam. Labrum graduated from Concord Law School, an online, non-ABA-accredited institution, and was admitted to practice law in California in 2021. She has since worked in Utah as a law clerk, mediator, and supervised pro bono attorney.The Utah State Bar denied Labrum's application to take the Utah bar exam, citing her insufficient years of practice. Labrum petitioned the Utah Supreme Court for a waiver, arguing that her education and experience met the rules' purposes and that her circumstances were extraordinary.The Utah Supreme Court reviewed the case and held that Labrum satisfied the burden of proof established in Kelly v. Utah State Bar. The court found that Concord's education, while not on par with ABA-accredited schools, was sufficient when combined with Labrum's practical experience. Her work in Utah, including her roles as a law clerk, mediator, and pro bono attorney, demonstrated her competence and ethical standards. The court also noted the significant changes in the accreditation of online law schools and the strong recommendations from Utah legal practitioners who supervised her work.The court concluded that Labrum's case was extraordinary due to the unique challenges she faced, her commitment to serving an underserved area in Utah, and the substantial support from the legal community. The Utah Supreme Court granted her petition for waiver, allowing her to take the Utah bar exam. View "Labrum v. Utah State Bar" on Justia Law

The case revolves around Brent Gordon's claim that Herriman City's policy violates his right to inspect records under the Utah Government Records Access and Management Act (GRAMA). Gordon did not appeal Herriman’s denial of a records request but instead sued for an injunction that would require Herriman to allow him to inspect any public record free of charge. The district court dismissed Gordon’s case, concluding that he needed to submit a formal records request and exhaust his administrative remedies before bringing suit.The district court agreed with Herriman City and dismissed Gordon’s claim. The court ruled that Gordon was not entitled to judicial review because he either did not make a formal GRAMA request or, if he did, he did not fully exhaust the administrative remedies associated with that request. Gordon appealed the district court’s decision to the Supreme Court of the State of Utah.The Supreme Court of the State of Utah affirmed the district court's decision. The court found that Gordon lacked statutory standing to pursue his claim. The court explained that the injunction provision in Utah Code section 63G-2-802(1), which Gordon relied on, merely provides a remedy and does not create a right of action. The court concluded that without an express or implied statutory right to seek judicial review of Herriman’s alleged policy, Gordon lacked statutory standing to pursue this action. Therefore, the district court lacked jurisdiction to adjudicate his GRAMA claim and correctly dismissed it. View "Gordon v. Nostrom" on Justia Law

In 2020, the Town of Hideout, Utah, took advantage of a brief window in state law that allowed municipalities to annex unincorporated areas without a petition or county consent. Hideout annexed an area in Summit County, and after receiving a certificate of annexation from the Lieutenant Governor, Summit County challenged the annexation and the related municipal ordinance in district court. The district court ruled in favor of Summit County, finding that it had standing to challenge the annexation and declaring the annexation ordinance invalid.The Supreme Court of the State of Utah reversed the district court's decisions. The court found that the relevant statutory scheme, the annexation code, did not provide Summit County with a legally protectible interest that would allow it to obtain the relief it sought. The court also found that the statutory provisions outside the annexation code that Summit County relied on did not provide it with a legally protectible interest in the controversy. The court further held that the doctrine of public interest standing, on which the district court alternatively relied, was inapplicable in this case.Because the court concluded that Summit County lacked standing to pursue its claims, it also reversed the district court’s award of summary judgment in Summit County’s favor without addressing the merits of Summit County’s claims. The case was remanded to the district court for dismissal. View "Hideout v. Summit County" on Justia Law

In 2018, a group of citizens in Tooele County, Utah, initiated the process to incorporate an area known as the City of Erda. The incorporation process involved several steps, including obtaining signatures from property owners within the proposed area, conducting a feasibility study, and holding a public vote. After the incorporation was certified by the Lieutenant Governor, three landowners within Erda's boundaries—John Bleazard, Mark Bleazard, and Six Mile Ranch Company—challenged the incorporation. They alleged that the incorporation process violated statutory requirements, including that their signatures were misrepresented in the feasibility study request and that the notice of impending boundary action was untimely.The district court in Tooele County denied motions to dismiss the case brought by the City of Erda and the Lieutenant Governor. They had argued that the landowners lacked statutory standing to challenge the incorporation. The court disagreed, finding that the landowners had a legally protectible interest under the Utah Code, which it interpreted as contemplating the possibility of a challenge to an incorporation.The Supreme Court of the State of Utah reversed the district court's decision. The Supreme Court held that the landowners' claim for declaratory relief was non-justiciable because they lacked a legally protectible interest in the controversy. The court found that the landowners did not have a private right of action to enforce the requirements of the incorporation code. The court concluded that the landowners' claim must be dismissed as a matter of law. View "Bleazard v. City of Erda" on Justia Law

In Utah, a group of local citizens sponsored the incorporation of an area in Tooele County to be known as the City of Erda. After the Lieutenant Governor certified Erda’s incorporation, three landowners within Erda’s boundaries challenged the incorporation, alleging statutory violations during the incorporation process. The defendants, Erda and the Lieutenant Governor, moved to dismiss the complaint, arguing that the landowners lacked statutory standing. The district court disagreed and denied their motions to dismiss.The defendants appealed to the Supreme Court of the State of Utah, arguing that the landowners' claim for declaratory relief should be dismissed as it is non-justiciable. The Supreme Court agreed, holding that the landowners’ claim must be dismissed as a matter of law because it is non-justiciable. The court found that under Utah law, a declaratory judgment action is non-justiciable if the plaintiff lacks a protectible legal interest in the controversy. The court concluded that the landowners did not have a protectible legal interest in their claim because the legislature did not grant affected citizens a private right of action to enforce the incorporation code’s requirements. Therefore, the court reversed the district court’s decision. View "Bleazard v. Henderson" on Justia Law

The case involves Salt Lake County's challenge to the constitutionality of the Aircraft Valuation Law, which provides a preferred method for determining the fair market value of aircraft for tax purposes. The County argued that the application of the law to Delta Air Lines' aircraft resulted in an assessment below fair market value, violating the Utah Constitution. The County also contended that the law, on its face, violated the Utah Constitution by divesting the Utah State Tax Commission of its power to assess airline property.The Utah State Tax Commission had previously upheld the 2017 assessment of Delta's property, which was calculated according to the Aircraft Valuation Law. The Commission found that the County did not provide clear and convincing evidence that the legislature's preferred method of valuation did not reasonably reflect fair market value.The Supreme Court of the State of Utah rejected the County's arguments. The court held that the County failed to fully utilize the statutory safety valve, which allows the Commission to use an alternative valuation method if the preferred method does not reasonably reflect fair market value. The court also rejected the County's facial challenge to the Aircraft Valuation Law, concluding that the County did not show that the law prohibits the legislature from prescribing a preferred method for valuing aircraft. Therefore, the court affirmed the Commission's decision. View "Salt Lake Co v. Tax Commission" on Justia Law

This case involved a group of businesses (referred to collectively as Taxpayers) who filed applications for adjustments to the fair market value of their properties for tax year 2020 in the state of Utah. They claimed that their properties' values had decreased due to "access interruption" caused by the COVID-19 pandemic and associated government guidelines, which they argued constituted a circumstance beyond their control under Utah Code section 59-2-1004.6 (the Access Interruption Statute).The Utah State Tax Commission rejected this argument, maintaining that the pandemic did not qualify as an "access interruption event" under the Access Interruption Statute. It reasoned that the statute applies only if access was interrupted due to any of thirteen enumerated events or due to a similar event as determined by the Commission via administrative rule. Because the pandemic neither fit into any of the enumerated categories nor was included in the Commission's administrative rules, the Commission ruled that the statute did not apply.The Supreme Court of the State of Utah agreed with the Commission's reasoning, holding that the Access Interruption Statute allows only the Commission to add to the statute’s list of qualifying circumstances if the Commission determines by rule that the additional event is similar to the events enumerated in the statute. Because the pandemic was not an enumerated event and had not been added by administrative rule, the Supreme Court upheld the Commission's decision. View "Miller Theatres v. Tax Commission" on Justia Law