Justia Utah Supreme Court Opinion Summaries

Steven Brown suffered a back injury while working as a school bus driver for the Washington County School District. Brown received workers’ compensation for this injury. In 2007, Brown was reinjured while attending a local festival. The School District denied workers’ compensation liability. An administrative law judge with the Labor Commission concluded that the prior industrial injury was a contributing cause to the second injury and awarded benefits. The Commission and court of appeals affirmed. After clarifying the causation standard under the direct and natural results test for interpreting the Workers’ Compensation Act, the Supreme Court remanded the case back to the Commission to determine whether Brown’s injury met this standard. View "Washington County Sch. Dist. v. Labor Comm'n" on Justia Law

In an equalization proceeding before the Utah State Tax Commission, Decker Lake Ventures, LLC sought a reduction of the assessed valuation of its property under Utah Code 59-2-1006. Under this statute, the Commission is directed to “adjust property valuations to reflect a value equalized with the assessed value of other comparable properties” upon a determination that “the property that is the subject of the appeal deviates in value plus or minus 5% from the assessed value of comparable properties.” The Commission rejected Decker Lake’s equalization claim. The Supreme Court affirmed, holding that the Commission did not commit reversible error in its determination of comparability or in its factual findings. View "Decker Lake Ventures v. Utah State Tax Comm'n" on Justia Law

Law Firm represented an employee in a workers’ compensation claim. Under a settlement agreement, the employee received a disability payment, part of which was earmarked as attorney fees. Defendant also agreed to pay the employee’s medical bills, which included bills from the University of Utah Health Care (Hospital). Law Firm sought to secure additional attorney fees from Hospital and filed an action alleging that it was entitled under a “common fund” theory to recover a percentage of the payments Hospital had received as a result of Law Firm’s efforts in pursuing the employee’s claim. The district court dismissed the action, concluding that the issue was a matter for the Labor Commission. The court of appeals affirmed. Law Firm subsequently asserted a claim before the Labor Commission against Hospital, again arguing for a right to recover fees on a common fund theory. An administrative law judge (ALJ) dismissed the claim, concluding that Law Firm had received all the fees it was statutorily due. Thereafter, Law Firm filed a further attempt at a common fund claim in the district court. The district court dismissed the claim, concluding that further litigation of the matter was barred by the doctrine of issue preclusion. The Supreme Court affirmed, holding that the elements of the doctrine of issue preclusion were amply satisfied in this case. View "Davis & Sanchez, PLLC v. Univ. of Utah Health Care" on Justia Law

Duane Serrano was injured in a car accident while driving a truck within the scope of his employment with Provo City. More than four years later, Serrano quit his job. Serrano subsequently applied for permanent total disability compensation under the Workers’ Compensation Act. On remand, an administrative law judge (ALJ) found that the preponderance of the evidence showed that Serrano was permanently and totally disabled as a result of his accident and awarded him permanent disability payments. The Utah Labor Commission affirmed. The Supreme Court affirmed, holding (1) Serrano proved the elements of a permanent total disability claim; (2) the ALJ did not abuse her discretion by initially denying Serrano’s claim but then awarding benefits after the Labor Commission instructed her to reconsider the evidence; and (3) award of benefits should not commence on the date that Serrano was deemed to be permanently and totally disabled because of the extraordinary delay in resolving Serrano’s claim. View "Provo City v. Utah Labor Comm’n" on Justia Law

Amy Sawyer was a special education teacher for the Jordan School District. When Sawyer received a failing score for her second Jordan Performance Appraisal System (JPAS) evaluation, Sawyer was informed that she would be required to pass a third JPAS evaluation to keep her job or that she could resign in order to avoid the third evaluation. Concerned that if she were terminated that she would not find future employment as a teacher, Sawyer elected to resign rather than submit to a third JPAS evaluation. The Department of Workforce Services (DWS) denied Sawyer’s application for unemployment benefits based upon its finding that Sawyer quit her job without good cause. An administrative law judge (ALJ) upheld DWS’s decision, and the Workforce Appeals Board affirmed. The Supreme Court reversed, holding (1) good cause to quit is a fact-like mixed question of law and fact reviewed deferentially; but (2) the ALJ and Appeals Board applied an incorrect legal standard to this mixed question. Remanded. View "Sawyer v. Dep’t of Workforce Servs." on Justia Law

In 2013, the Utah Public Service Commission (PSC) approved power purchase agreements between PacifiCorp and two small power producers. Under these agreements, PacifiCorp’s Rocky Mountain Power division would become obligated to purchase all power produced by the producers’ clean energy wind projects. Ellis-Hall Consultants, a competitor of the two small power producers, intervened in the PSC proceedings and subsequently appealed. The Supreme Court affirmed the PSC’s decision, holding (1) the power purchase agreements did not contravene the terms of an applicable regulatory tariff referred to as Schedule 38; (2) PacifiCorp did not engage in discrimination in its application of the terms of Schedule 38; and (3) the power purchase agreements were enforceable. View "Ellis-Hall Consultants, LLC v. Pub. Serv. Comm’n of Utah" on Justia Law

Plaintiffs filed a complaint against America West Bank, L.C. (the Bank) alleging, among other claims, improper acceptance of unauthorized signatures. The Bank tendered defense of the claim to its insurer under the terms of a financial institution bond. The Utah Department of Financial Institutions subsequently closed the Bank and appointed the Federal Deposit Insurance Corporation (FDIC) as receiver. The FDIC mailed and published notices indicating that all claims against the Bank had to be submitted to the FDIC for administrative review. After the administrative claims review deadline, Plaintiff filed a proof of claim with the FDIC, which the FDIC disallowed because it was untimely filed. Plaintiffs then filed a notice of intent to prosecute. The district court granted the FDIC’s motion to dismiss, concluding that Plaintiffs failed to exhaust the administrative claims review process made available to them by the Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA). The Supreme Court affirmed, holding (1) Plaintiffs’ failure to comply with the administrative exhaustion requirements of FIRREA deprived the district court of subject matter jurisdiction; and (2) Plaintiffs’ failure to avail themselves of the available claims review process did not amount to a violation of due process. View "Summerhaze Co., L.C. v. Fed. Deposit Ins. Corp." on Justia Law

The Utah Department of Transportation (UDOT) condemned a fifteen-acre parcel owned by Michael Carlson despite the fact that it needed just over one acre for its planned project. At issue in this case was whether Utah Code 72-5-113 authorized UDOT’s condemnation of the excess property and whether the taking failed for lack of a “public use” as required under the Takings Clause of the Utah Constitution or United States Constitution. The Supreme Court agreed with UDOT’s construction of section 113 and granted summary judgment in favor of UDOT without expressly addressing the constitutionality of the taking. The Supreme Court (1) affirmed the district court’s endorsement of UDOT’s statutory authority to condemn excess property for transportation purposes; but (2) reversed and remanded to allow the district court to determine the constitutionality of UDOT’s condemnation of Carlson’s excess property. View "Utah Dep’t of Transp. v. Carlson" on Justia Law

US Oil Sands, Inc. applied for a discharge permit from the Utah Board of Water Quality (BWQ) for its tar sands bitumen-extraction project. In 2008, the BWQ issued the discharge permit. The 2008 decision was reaffirmed by the Executive Secretary in 2011. Living Rivers, an environmental advocacy organization, intervened and sought administrative review of the Secretary’s decision. The BWQ affirmed the issuance of the 2008 permit on its merits. Living Rivers petitioned for review of the BWQ’s decision. The Supreme Court dismissed the case for lack of jurisdiction, holding that because was no timely challenge to the 2008 decision, the original permit was final and not subject to further challenge on the merits. View "Living Rivers v. Utah Div. of Water Quality" on Justia Law

John Dorsey filed a series of unemployment claims for time periods when he was in Mexico during the offseason of his employment at a Utah resort. Because he was considered a seasonal employee Dorsey was granted a deferral from the requirement of search for work as a prerequisite to eligibility for benefits. The Department of Workforce Services later concluded that Dorsey had been ineligible to receive unemployment benefits during his trips to Mexico under its rule deeming unemployment claimants ineligible for benefits if they travel outside the United States for more than two weeks. The Workforce Appeals Board affirmed. The court of appeals reversed. The Supreme Court affirmed, holding (1) the Department's rule as extended to a seasonal worker not required to search for work is incompatible with the governing statutory position; and (2) because Dorsey was “able” and “available” for work he was eligible for unemployment benefits under the statute. View "Dorsey v. Dep’t of Workforce Servs." on Justia Law