Justia Utah Supreme Court Opinion Summaries

Defendant worked for Plaintiff, a technology company, as an engineer. During and after her employment with Plaintiff, Defendant forwarded confidential emails to her private Gmail account, copied a confidential business plan to a thumb drive, and placed protected information on the record in an administrative proceeding. Plaintiff filed suit, alleging that Defendant had violated a non-disclosure agreement and misappropriated company trade secrets. The district court granted summary judgment for Defendant, determining that Plaintiff had failed to make an adequate showing of harm. The court further entered Utah R. Civ. P. 11 sanctions against Plaintiff and awarded attorney fees to Defendant. The Supreme Court reversed, holding (1) there was sufficient evidence of threatened harm - or at least genuine issues of material fact concerning such harm - to defeat Plaintiff’s motion for summary judgment; and (2) because Plaintiff prevailed on Defendant’s motion for summary judgment, Defendant could not be entitled to sanctions or fees. View "Innosys v. Mercer" on Justia Law

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

Employer, a steel mill, fired Employee on suspicion that Employee had misappropriated steel from the company. In firing him, Employer refused to pay Employee the commissions he claimed to have earned, asserting that it could withhold the commissions as an offset against the value of the misappropriated steel. Employee filed this action claiming that Employer had violated the Utah Payment of Wages Act (UPWA). The district court granted summary judgment for Employee, concluding that the UPWA did not permit a preemptive withholding of Employee’s commissions. The Supreme Court reversed, holding that the statute allows an employer in a case such as this one to seek a post-withholding opinion of a court or administrative law judge that an offset was warranted. Remanded for a determination whether Employer had presented evidence that in the opinion of the district court would warrant an offset sufficient to justify Employer’s withholding of Employee’s unpaid commission. View "Utley v. Mill Man Steel, Inc." on Justia Law

Plaintiff, an attorney, filed a complaint against his employer, alleging that he was terminated for refusing to violate the Utah Rules of Professional Conduct. Specifically, Plaintiff alleged that he was fired for refusing to break the law by complying the company’s ongoing violation of usury laws in numerous states. The district court dismissed the complaint, concluding that Plaintiff was an at-will employee and that his termination did not violate a clear and substantial public policy of the state. The Supreme Court affirmed, holding (1) the district court properly dismissed Plaintiff’s wrongful termination claim, where Plaintiff failed to invoke a clear and substantial public policy that would have prohibited his employer from terminating him, and where rule 1.13(b) of the Utah Rules of Professional Conduct does not reflect the type of public policy that prevents the termination of an at-will employee; and (2) the district court erred when it denied Plaintiff’s request for a hearing, but the error was harmless. View "Pang v. Int’l Document Servs." on Justia Law

Plaintiff, an attorney, filed a complaint against his employer, alleging that he was terminated for refusing to violate the Utah Rules of Professional Conduct. Specifically, Plaintiff alleged that he was fired for refusing to break the law by complying the company’s ongoing violation of usury laws in numerous states. The district court dismissed the complaint, concluding that Plaintiff was an at-will employee and that his termination did not violate a clear and substantial public policy of the state. The Supreme Court affirmed, holding (1) the district court properly dismissed Plaintiff’s wrongful termination claim, where Plaintiff failed to invoke a clear and substantial public policy that would have prohibited his employer from terminating him, and where rule 1.13(b) of the Utah Rules of Professional Conduct does not reflect the type of public policy that prevents the termination of an at-will employee; and (2) the district court erred when it denied Plaintiff’s request for a hearing, but the error was harmless. View "Pang v. Int’l Document Servs." 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

Employees and others founded Nuriche, LLC, a now-defunct limited liability company formed in Nevada and registered to do business in Utah. After being terminated, Employees filed this complaint alleging that Nuriche and members of its board of managers (Managers) breached their agreement to pay Employees a certain amount of compensation in annual salaries and benefits and violated the Utah Payment of Wages Act (UPWA) by failing to pay past-due wages following Employees’ termination. The district court granted Managers’ motion for summary judgment, ruling that the UPWA does not extend wage liability to individual managers. The Supreme Court affirmed, holding (1) the question of Managers’ liability for unpaid wages is governed by Utah law; and (2) Managers could not be held personally liable for the unpaid wages claimed by Employees under the UPWA because Managers did not personally employ Employees but instead were acting as agents of Nuriche. View "Heaps v. Nuriche, LLC" on Justia Law

Vickie Warrant filed a personal injury suit against Defendants seeking damages due to her exposure to asbestos, which she claimed caused her mesothelioma. After receiving a jury verdict in her favor in the personal injury lawsuit, Warren died. Thereafter, Micah Riggs, the personal representative of Warren’s estate, filed a wrongful death and survival suit on behalf of Warren’s children that arose out of the same injury and was against the same defendants. Defendants moved to dismiss the wrongful death claim, asserting that Warren’s personal injury trial and judgment precluded the wrongful death motion. The district court denied the motion. The Supreme Court affirmed, holding that a prior personal injury suit does not bar a related wrongful death claim brought by the decedent’s heirs or personal representative. View "Riggs v. Georgia-Pacific LLC" on Justia Law