Justia Utah Supreme Court Opinion Summaries

A group of residential tenants (collectively, Tenants) alleged claims of negligence against Canyon Cover Properties, LLC and Apartment Management Consultants, LLC (collectively, AMC). AMC argued that it was relieved from liability because Tenants signed a residential lease agreement (Agreement) that included a limited liability provision (Exculpatory Clause) waiving the right to bring an action for negligence against AMC. The district court concluded that the Agreement and Exculpatory Clause did not violate public policy and were therefore valid and enforceable, and accordingly, granted summary judgment for AMC. The Supreme Court reversed, holding that because AMC failed to respond meaningfully to Tenants' claim that the Exculpatory Clause was unenforceable because it violated public policy, AMC's brief was rejected and Tenants' claim was accepted that the Exculpatory Clause in the Agreement was unenforceable. Remanded. View "Broderick v. Apartment Mgmt. Consultants, LLC" on Justia Law

After sustaining injuries in an auto accident, Tavis McArthur filed this suit in federal district court to recover underinsured motorist (UIM) benefits under his State Farm automobile insurance policy. The district court granted summary judgment in favor of State Farm, concluding that McArthur had failed to exhaust the liability limits of the tortfeasor's insurance, a precondition of his UIM benefits policy. On appeal, the Tenth Circuit Court of Appeals certified two questions to the Utah Supreme Court. The Supreme Court held (1) exhaustion clauses that require the liability insurer to pay out its full policy limits before permitting payment of UIM benefits are generally enforceable in the State of Utah; and (2) because UIM exhaustion provisions are conditions precedent and not covenants capable of being breached, no showing of prejudice is required to sustain their invocation. View "McArthur v. State Farm Mut. Auto. Ins. Co." on Justia Law

When Client allegedly failed to pay Firm as agreed under their contract, Firm sued Client for breach. Client counterclaimed for breach of contract and negligence. Client also filed a third-party complaint against Firm's Owner, alleging that Owner was Firm's alter ego and seeking to hold Owner liable for any judgment entered against Firm. The trial court entered (1) a directed verdict on the third-party complaint, and (2) judgment in favor of Client on Firm's breach of contract claim and on Client's counterclaim against Firm. Owner later sought attorney fees under the reciprocal attorney fees statute, Utah Code Ann. 78B-5-826, arguing that, as the prevailing party in the third-party action, he was entitled to a fee. The trial court denied Owner's request, concluding that Owner was not a party to the contract as required to trigger the statute. The court also denied Owner's request for costs. The court of appeals affirmed. The Supreme Court (1) affirmed the court of appeals' decision as to attorney fees under its analysis in Hooban v. Unicity International Inc.; but (2) reversed the court of appeals' decision as to costs based on its reading of Utah R. Civ. P. 54(d). Remanded. View "Bushnell v. Barker" on Justia Law

Dillon Whitney's mother filed a wrongful death suit against the State after Dillon died while in state custody. The State filed a motion to dismiss, arguing that it was exempt from suit under the incarceration exception to the Governmental Immunity Act of Utah. The federal district court denied the motion, and the State appealed. The Supreme Court accepted certification to answer a question of state law and held (1) a juvenile who is placed in an unsecured community-based proctor home is not incarcerated in a place of legal confinement; and (2) accordingly, the incarceration exception to the State's waiver of its sovereign immunity did not apply in this case, and the State remained potentially liable for damages related to Dillon's death. View "Whitney v. Div. of Juvenile Justice Servs." on Justia Law

Patient received medical treatment from Nurse at Medical Clinic. Nurse prescribed Patient at least six medications. With all of these drugs in his system, Patient shot and killed his wife. Patient subsequently pled guilty to aggravated murder. Patient's children (Plaintiffs) filed suit through their conservator against Nurse, her consulting physician, and Medical Clinic (collectively Defendants), alleging negligence in the prescription of the medications that caused Patient's violent outburst and his wife's death. The district court granted Defendants' motion to dismiss, concluding that Nurse owed no duty of care to Plaintiffs because no patient-health care provider relationship existed at the time of the underlying events between Plaintiffs and Defendants. The Supreme Court reversed, holding that healthcare providers owe nonpatients a duty to exercise reasonable care in the affirmative act of prescribing medications that pose a risk of injury to third parties. View "Jeffs v. West" on Justia Law

The parents of a child who suffered an injury during an adult softball game sued the United States Specialty Association (USSSA) and several other defendants. At the time of the accident, USSSA was insured by United States Fidelity and Guarantee Co. (USF&G). USF&G assumed the defense of USSSA, and a jury entered a verdict against USSSA. USF&G posted a bond of $4 million to secure the remainder of the judgment and, simultaneously, filed an action in federal court seeking a judicial declaration that it could not be compelled to pay more than the $2 million policy limit. USSSA later moved for partial summary judgment, contending that USF&G had no right to restitution against its insured for the amounts paid in excess of policy limits. The Supreme Court accepted certification to answer questions of law that controlled the parties' motions, answering (1) an insurer may not seek restitution based on the theory of unjust enrichment where there is an express contract governing the subject matter of the dispute; and (2) an insurer's right to reimbursement from an insured affects the parties' risk relationship and therefore may only arise under the express terms of their insurance contract. View "U.S. Fid. & Guar. Co. v. U.S. Sports Specialty Ass'n" on Justia Law

In 2000, a fire destroyed a business location of Stone Flood and Fire Restoration Inc., spurring years of litigation with its insurer, Safeco Insurance Company of America. After Stone Flood and its two shareholders, James and Patrice Stone, sued Safeco in 2007, the district court dismissed all claims against Safeco. The court concluded (1) Stone Flood's claims on the insurance policy were filed three days beyond the applicable statute of limitations and were therefore barred; (2) the Stones were not insureds and lacked standing to bring individual claims under the policy; and (3) the Stones lacked standing to bring a claim of intentional infliction of emotional distress (IIED) because their alleged injuries were merely derivative of the corporation's. The Supreme Court reversed in part and affirmed in part, holding (1) the district court's calculation of the tolling of the limitations period was incorrect and a correct calculation saved Stone Flood's claims under the insurance policy; and (2) the district court properly concluded the Stones were not insureds and lacked standing to sue under the policy, and their claim of IIED failed for lack of a distinct, non-derivative injury. Remanded. View "Stone Flood & Fire Restoration, Inc. v. Safeco Ins. Co." on Justia Law

After giving birth to a stillborn male, Father and Mother filed suit against the United States in federal district court, alleging medical negligence and requesting damages for their pain and suffering, for the wrongful death of their child, and for expenses related to their child's death. The Supreme Court accepted certification to answer whether Utah Code Ann. 78-11-6 allows a claim to be made for the wrongful death of an unborn child. At the time the claim was filed, Utah's wrongful death statute stated that "a parent or guardian may maintain an action for the death or injury of a minor child when the injury or death is caused by the wrongful act or neglect of another." Although there was no majority opinion, four members of the Court held that the statute allows an action for the wrongful death of an unborn child because the term "minor child," as used in the statute, includes an unborn child. View "Carranza v. United States" on Justia Law

The underlying dispute in this appeal revolved around the issue of who was contractually obligated to pay workers' compensation benefits to an employee of Employer. The Supreme Court found that Employer's Insurer was required to pay workers' compensation benefits for all of Employer's employees and remanded the case. The district court entered a final judgment. Instead of filing a notice of appeal within thirty days of the district court's judgment, Insurer filed an "objection to judgment." Insurer then filed its notice of appeal within thirty days of the district court's order disposing of that motion. The Supreme Court dismissed the appeal, holding that it lacked jurisdiction to address the appeal as (1) Insurer did not file its notice of appeal within thirty days of the district court's final judgment, and (2) Insurer failed to file a postjudgment motion that would toll the time for appeal or one that the Court had jurisdiction to review. View "Workers Comp. Fund v. Argonaut Ins. Co." on Justia Law

Andrew Allen filed a complaint against Melissa Moyer in small claims court for property damage arising out of an automobile accident. The small claims court awarded Allen a judgment for the damage to his car. After Moyer paid the judgment amount, Allen filed a separate action against Moyer in the district court for personal injuries arising out of the accident. The district court granted summary judgment in favor of Moyer, concluding that Allen's claim was barred by the doctrine of claim preclusion. At issue on appeal was whether claim preclusion is applicable to small claims judgments. The Supreme Court affirmed, holding that the doctrine of claim preclusion applies to small claims judgments because application of the doctrine will promote finality, judicial economy, and consistent judgments. View "Allen v. Moyer" on Justia Law