Justia Utah Supreme Court Opinion Summaries

Kelly Colvin was killed in an automobile accident while returning to Utah from a work project in Maryland. The accident occurred when Colvin was a passenger in a vehicle driven by his coworker, Joseph Giguere. Colvin’s widow and son sued Giguere, claiming that Colvin’s death was proximately caused by Giguere’s negligent driving. Giguere moved for summary judgment, asserting that the exclusive remedy provision of the Workers’ Compensation Act barred this suit because the accident occurred in the course of his and Colvin’s employment. The district court agreed and granted Giguere’s motion for summary judgment. The Supreme Court affirmed, holding that because the accident occurred while Colvin and Giguere were carrying out a special errand for their employer, this action was barred under the Act’s exclusive remedy provision. View "Colvin v. Giguere" on Justia Law

Plaintiffs, employees of Kane County Hospital, sued various parties, including Utah Retirement Systems (URS), based on the Hospital’s alleged failure to adequately fund their retirement benefits as required by the Utah State Retirement and Insurance Benefit Act (“Act”). Before Plaintiffs filed their lawsuit, URS initiated an administrative proceeding against the Hospital, pursuant to the Act, seeking recovery of unpaid benefit contributions for Hospital employees. The district court dismissed Plaintiffs’ claims for lack of jurisdiction because Plaintiffs had not exhausted their administrative remedies. The court of appeals reversed and ordered that the case be stayed pending resolution of URS’s administrative action against the Hospital, concluding that it was impossible to ascertain which claims were subject to the exhaustion requirement until the pending administrative action was resolved. The Supreme Court reversed, holding that it lacked jurisdiction over Plaintiffs’ claims based on their failure to exhaust their administrative remedies because all of the claims fell within the scope of the Act and none of the exceptions to exhaustion applied. View "Ramsay v. Kane County Human Res. Special Serv. Dist." on Justia Law

The Utah Occupational Safety and Health Division (UOSH) cited and fined Hughes General Contractors, which oversaw a construction project involving over 100 subcontractors, for a subcontractor’s violation on the project. In determining that Hughes was responsible for safety conditions for the subcontractor’s employees, the UOSH invoked the multi-employer worksite doctrine, which makes a general contractor responsible for the occupational safety of all workers on a worksite, including those who are not the contractor’s employees. Both an administrative law judge and the Labor Commission’s Appeals Board upheld the citation and the multi-employer worksite doctrine, which federal OSHA regulations have adopted and federal courts have upheld. The Supreme Court reversed the citation and penalty, holding (1) the multi-employer worksite doctrine is incompatible with the governing Utah statute, Utah Code 34A-6-201(1; (2) the responsibility for ensuring occupational safety under the governing statute is limited to an employer’s responsibility to its employees; and (3) because Hughes was not an employer of the workers in question in this case, Hughes was improperly cited and sanctioned. View "Hughes Gen. Contractors, Inc. v. Utah Labor Comm’n" on Justia Law

Wade Marinoni was employed as a first-response emergency medical technician (EMT) for Carbon County. After an incident involving an immediate transport of a patient having a heart attack, Marinoni was fired for failing to immediately respond to the transport request. Marinoni applied for and was awarded unemployment benefits. The ALJ affirmed, finding that Marinoni had acted in good faith according to his understanding of his employer's protocol. The Workforce Board of Appeals affirmed, concluding that Carbon County did not meet its burden to demonstrate just cause for termination. The Supreme Court affirmed the court of appeals' ultimate determination upholding the award of unemployment benefits, holding (1) the court of appeals erred in declining to consider in its legal analysis the uncontested fact that Marinoni knew the patient was having a heart attack; but (2) the Board's legal conclusions regarding culpability were within the scope of the deference granted to the Board's decision. View "Carbon County v. Workforce Appeals Bd." on Justia Law

Petitioner was working as a park ranger for Utah State Parks and Recreation when he suffered pain in his lower back after losing then regaining his balance on a boat dock while preparing to go on boating patrol. The Utah Labor Commission denied Petitioner's claim for benefits, concluding that the accident had aggravated a preexisting lower back condition and but that the unexpected wave that caused Petitioner to slightly lose his balance was not the legal cause of Petitioner's injury. The court of appeals affirmed. The Supreme Court upheld the court of appeals' ultimate decision to deny Petitioner compensation benefits; holding (1) the court of appeals erred in applying an abuse of discretion standard of review to the Commission's decision; but (2) even under a nondeferential standard of review, Petitioner failed to establish that his boat accident, rather than his preexisting back condition, was the legal cause of his injury.View "Murray v. Utah Labor Comm'n" 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

Capital Assets Financial Services, the owner of property within the City of Saratoga Springs, asked the city council to rezone its property from a low density to a medium density residential zone. The city council granted the request. A group of citizens submitted a petition to the City requesting that the site-specific rezoning be placed on the ballot as a referendum. The City granted the request. Capital Assets subsequently filed a complaint against the City requesting a declaration that the action of the city council was made through its administrative, and not legislative, power. The district court ruled in favor of Capital Assets, declaring that the site-specific zoning was administrative and thus not subject to referendum, and enjoining the City from placing the referendum on the ballot. Thereafter, the citizens' group filed a petition for an extraordinary writ. The Supreme Court granted the petition and directed the City to place the referendum on the ballot, holding that the site-specific rezone of Capital Assets' property was a legislative matter and thus subject to referendum. View "Krejci v. City of Saratoga Springs" on Justia Law

In 1990, Chin Lee established a defined-benefit plan, which he converted in 1996 into a profit-sharing plan, both of which were qualified plans. Chin's sole proprietorship contributed funds to the Plan from 1990 to 1995. These funds were invested entirely in U.S. government obligations, the interest on which was tax-exempt. In their 2005 and 2006 tax filings, Chin and Yvonne Lee reported Plan distributions and claimed deductions for federal obligation interest that the Plan earned in those and in earlier years. The Utah State Tax Commission disallowed these deductions, concluding that the Lees' distributions from the Plan were not exempt from state taxation even though the Plan assets were invested solely in U.S. government obligations. The Supreme Court affirmed, holding that no portion of the Plan distributions was tax-exempt, as (1) the distributions from the Plan qualified for a tax exemption only if the Plan acted as a conduit, allowing the funds to retain their tax-exempt character after distribution; and (2) the Lees' qualified profit-sharing plan was a non-conduit entity, and thus, the funds did not retain their character as interest on U.S. obligations upon distribution to the Lees. Therefore, the distributions were fully taxable by Utah.View "Lee v. Utah State Tax Comm'n " on Justia Law

Officer Dennis Nelson, a police officer with the Orem City Police Department (OCPD), was terminated from his position for using excessive force during a booking at the Orem City Jail. The Orem City Employee Appeals Board (Board) upheld the termination. The court of appeals upheld the Board's decision, concluding (1) the OCPD's decision to terminate Nelson was not inconsistent with prior instances of discipline under OCPD's excessive force policy; (2) alternatively, the Board justified any disparate application of OCPD's policy; and (3) the Board did not violate Nelson's procedural due process rights at his hearing before the Board. The Supreme Court affirmed, holding (1) the court of appeals did not err in applying an abuse of discretion standard of review; and (2) the court of appeals correctly found that any procedural due process violations at the hearing were harmless. View "Nelson v. City of Orem" on Justia Law

In connection with the Utah Transit Authority's construction of a high-speed commuter rail line, the Utah Department of Transportation (UDOT) classified a certain railroad crossing as public. The Public Service Commission upheld the classification. Union Pacific Railroad sought review of the Commission's decision upholding UDOT's public classification. The Supreme Court affirmed, concluding that the Commission did not err in determining that UDOT correctly classified the crossing as public, as Union Pacific failed to present enough evidence to support its arguments that the crossing was formally vacated or abandoned or that the crossing was a new road that never became public. View "Union Pac. R.R. v. Utah Dep't of Transp." on Justia Law