Justia Utah Supreme Court Opinion Summaries

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

Petitioner was traveling home from work in his personal vehicle when he sustained back injuries in a car accident. Petitioner applied for workers' compensation benefits, but his application was denied under the "going and coming rule," which deems injuries occurring during a work commute outside the course of employment and thus not compensable. Petitioner appealed, arguing that in light of the benefits his employer received through various work-related uses of his vehicle, he was "in the course of employment" during the accident. The labor commission and court of appeals rejected Petitioner's claim that he qualified under the "instrumentality" exception of the going and coming rule. The Supreme Court affirmed, holding that Petitioner fell within the rule and not the exception. View "Jex v. Utah Labor Comm'n" on Justia Law

In 2003, the City of Salt Lake asked voters to approve Proposition No. 5, which proposed the issuance of bonds to finance construction of a regional sports, recreation, and education complex. Voters approved the bonds. In 2011, the City authorized issuance of the bonds with Resolution No. 5 and then filed a petition to validate the Proposition No. 5 bonds in district court. Appellants, the Jordan River Restoration Network and several citizens, appeared pro se to oppose the City's petition, challenging the bonds' validity on several statutory and constitutional grounds. The district court denied Appellants' claim and granted the City's validation petition. The Supreme Court affirmed the City's validation petition, holding (1) the district court conducted the validation proceedings in compliance with due process and the Validation Act; and (2) the district court correctly applied the Local Government Bonding Act. View "Salt Lake City Corp. v. Jordan River Restoration Network" on Justia Law

This case required the Supreme Court to determine when a well "started" under Utah Code 59-5-102. Although that statute imposes a severance tax on oil or gas produced from a well, section 59-5-102(5)(c) permits an exemption for "the first six months of production for development wells started after January 1, 1990." Summit Operating, LLC argued that a well starts when it begins commercial production. Under this interpretation, Summit asserted that it was entitled to a six-month tax exemption for its well, which started commercial production in 2008. The Utah State Tax Commission asserted that a well starts on the date that drilling begins, and thus, Summit was not entitled to the tax exemption because drilling for Summit's well began in 1983. The Supreme Court affirmed the Commission's order granting summary judgment to the Auditing Division of the Commission, holding that under the Tax Exemption Statute, a well "starts" when drilling begins. View "Summit Operating v. State Tax Comm'n" on Justia Law

This appeal resulted from an action in eminent domain in which the Utah Department of Transportation sought to condemn an access point easement on property owned by FPA West Point. FPA's codefendant and lessee, Kmart Corporation, also claimed an interest in the access. Because of the different interests claimed by FPA and Kmart, FPA filed a motion asking the court to order separate just compensation determinations. The district court granted the motion. The Supreme Court held (1) the district court was correct in determining that the values of respective interests in a parcel of condemned property must be individually assessed; (2) the value of respective interests may be individually assessed in either separate or consolidated proceedings; (3) accordingly, the district court has discretion to order separate proceedings in an action involving multiple interest holders in a condemned parcel of property; and (4) because it was unclear whether the district court intended that FPA's and Kmart's interests be assessed through separate or through consolidated proceedings, the case was remanded with instructions to determine whether to order separate or consolidated proceedings in this matter. View "Utah Dep't of Transp. v. FPA West Point, LLC" on Justia Law

Sunnyside Coal Company (Sunnyside), the Employers' Reinsurance Fund (ERF), and the Workers' Compensation Fund (WCF) (collectively, Petitioners) challenged the Labor Commission's award of permanent total disability benefits to Claimant. Petitioners argued that the award was barred under the relevant statute of limitation, which prevented the labor commission from acquiring jurisdiction and making the award. The Supreme Court affirmed the commission's award of permanent total disability benefits but remanded for a determination of the correct amount of compensation, holding (1) the commission correctly determined it had original jurisdiction over the claim and also correctly exercised its continuing jurisdiction in awarding compensation; (2) because of the long delay in bringing the claim, however, Claimant's recovery was equitably limited; and (3) ERF was obligated to pay only prospective benefits from the date of filing, and Sunnyside and WCF were not liable for any permanent total disability benefits. View "Employers' Reinsurance Fund v. Henningson" on Justia Law

The Board of Oil, Gas and Mining (Board) affirmed the approval by the Division of Oil, Gas and Mining (Division) of Alton Coal Development's (ACD) mining permit, which allowed ACD to conduct surface coal mining operations at the Coal Hollow Mine. Petitioners appealed, arguing that the Board erred in affirming ACD's permit because the permit application was deficient in several respects. The Supreme Court affirmed the Board's decision, holding (1) the Board properly concluded that the Division gave adequate consideration to cultural and historic resources in the adjacent area; (2) the Board properly concluded that the Division's cumulative hydrological Impact Assessment satisfied Utah's requirements; (3) the Board properly concluded that the hydrologic monitoring plan was adequate; and (4) therefore, the Board acted within its discretion in affirming the Division's conclusions that ACD's mining permit application satisfied all of the statutory and regulatory requirements. View "Sierra Club v. Bd. of Oil, Gas, & Mining" on Justia Law

This appeal concerned a challenge by a group of citizens (Citizens) to an ordinance passed by the Ground County Council (Council) approving amendments concerning a Planned Unit Development district. The district court granted summary judgment in favor of the Council and the developer. In the district court, Citizens claimed the Council had acted administratively in adopting the ordinance, and accordingly, the matter should be remanded to the county board of adjustments because Citizens weren't allowed to challenge an administrative decision in a district court until they had exhausted their administrative remedies. The Supreme Court affirmed, holding (1) the Council acted in its legislative capacity in adopting the ordinance because the ordinance created a new law of general applicability passed after the Council weighed policy considerations and because it had the formal nature of a legislative act; and (2) the ordinance should not be set aside because of illegality because, for each of Citizens' claims, the Council complied with applicable zoning ordinances. View "Suarez v. Grand County" on Justia Law

One of Summit Water Distribution Company's (SWDC) minority shareholders, Bear Hollow Restoration, filed a complaint requesting a review and investigation of SWDC's exemption from public regulation under the now-repealed Utah Admin. R. 746-331-1. The Public Service Commission dismissed the complaint on the basis that SWDC was not a public utility, and therefore, the Commission did not have jurisdiction. The Supreme Court affirmed the Commission's dismissal, holding (1) the allegations in Bear Hollow's complaint were insufficient to establish that SWDC served the public generally or that the Commission had jurisdiction; (2) Bear Hollow was not prejudiced by repeal of Rule 746-331-1 because the rule applied only to internal agency decisions and the underlying substantive law remained in place; and (3) the Commission did not abuse its discretion when it refused Bear Hollow's amended complaint after the original complaint had been dismissed. View "Bear Hollow Restoration, LLC v. Utah Pub. Serv. Comm'n" on Justia Law