Justia Utah Supreme Court Opinion Summaries

After a car accident in which the defendant, while driving a marked police vehicle, rear-ended the plaintiff’s car, the plaintiff sought medical treatment at a hospital and received an initial bill for $7,175.77 for emergency care and $92 for an eye exam. However, due to a preexisting contract between the plaintiff’s health insurer and the hospital, the insurer paid a reduced, negotiated amount—$4,395.75 for the emergency care—which fully satisfied the bill. The plaintiff then sued the defendant for negligence, seeking special damages for past medical expenses based on the gross charges listed on the hospital bill.In the Third District Court, Salt Lake County, both parties filed motions in limine regarding the admissibility of the gross charges versus the negotiated charges. The district court ruled that, under the collateral source rule, evidence of the negotiated charges paid by the plaintiff’s insurance was inadmissible, and only the gross charges could be considered. At a bench trial, the court awarded the plaintiff special damages based on the gross charges, less a deduction for amounts already reimbursed by the defendant to the plaintiff’s car insurance provider.On direct appeal, the Supreme Court of the State of Utah addressed whether the collateral source rule requires exclusion of evidence of the negotiated charges for an insured plaintiff’s medical care. The court held that the collateral source rule does not require exclusion of the negotiated charges, because the gross charge does not reflect the plaintiff’s actual loss; neither the plaintiff nor the insurer was ever obligated to pay the gross amount. The court concluded that only the negotiated charge represents the compensable loss for special damages. Accordingly, the Supreme Court of Utah vacated the special damages award and remanded for a new trial on that issue. View "Gardner v. Norman" on Justia Law

This case arises from a 2004 automobile accident in which one driver, LaMoin Larkin, died. Larkin’s insurer paid benefits to his estate and then sued the surviving driver, Jared Weston, for negligence, also seeking a declaratory judgment that Weston was insured by Farmers Insurance Exchange at the time of the accident. Farmers Insurance Exchange denied coverage, claiming the policy had been cancelled prior to the accident. Weston filed a crossclaim against Farmers, alleging breach of the duty to defend. Weston and Larkin’s insurer arbitrated the negligence claim, resulting in a finding of liability against Weston and a judgment entered in 2009.The Third District Court, Salt Lake County, confirmed the arbitration award and entered judgment. It later held a bench trial to resolve whether Farmers had properly cancelled Weston’s policy, ultimately finding the cancellation was valid and that Weston was not insured at the time of the accident. The court also granted summary judgment that Farmers had breached its duty to defend Weston, as the complaint raised a genuine issue regarding cancellation. Subsequent proceedings addressed damages, including emotional distress and attorney fees. The district court found Weston failed to prove emotional distress caused by the breach and reduced damages to zero. The court also ruled that the 2009 judgment had not expired, allowing it to be amended to include interest and costs.The Utah Court of Appeals affirmed the district court’s findings on cancellation, breach of duty to defend, and emotional distress, but reversed on consequential damages, holding Farmers liable for the arbitration judgment and related attorney fees. On certiorari, the Supreme Court of the State of Utah held that the 2009 judgment expired in 2017 under Utah law, reversing the court of appeals on that issue and vacating the award of damages and attorney fees based on the expired judgment. The Supreme Court affirmed that Farmers breached its duty to defend but found no basis for damages or attorney fees due to the expiration of the judgment. View "Farm Bureau v. Weston" on Justia Law

A man with severe chronic pain had long been prescribed oxycodone. When he visited his doctor for an unrelated issue, he was also prescribed clonazepam, a benzodiazepine. The combination of these two drugs carries a significant risk of respiratory depression and death, a fact underscored by an FDA-mandated black box warning. The man and his wife expressed concern about the new prescription, but his doctor reassured them. When the prescription for clonazepam was filled at a pharmacy, the pharmacist’s computer system flagged a warning about the dangerous interaction with oxycodone. The pharmacist overrode the warning and dispensed the medication. The man died the next day from toxicity due to both drugs.The man’s family and estate sued the pharmacy, alleging negligence, including a failure to warn about the drug interaction. The Third District Court, Salt Lake County, denied the pharmacy’s motion for summary judgment, which was based on the “learned intermediary rule.” This rule generally exempts pharmacists from warning patients about the general risks of FDA-approved drugs, on the assumption that the prescribing physician is best positioned to provide such warnings. The district court found that there were material factual disputes about whether the pharmacist knew of a patient-specific risk and whether the learned intermediary rule applied.The Supreme Court of the State of Utah reviewed the case on interlocutory appeal. It held that the learned intermediary rule does not shield a pharmacist from liability when the pharmacist is aware of a patient-specific risk, as opposed to general risks associated with a drug. The court affirmed the district court’s denial of summary judgment, clarifying that pharmacists retain a duty to act as a reasonably prudent pharmacist would when aware of such risks. The case was remanded for further proceedings. View "Walgreen v. Jensen" on Justia Law

A teacher at a public charter school in Utah was terminated after a series of events involving a student and the student's parent. The teacher, a former Air Force veteran, reprimanded the student for disruptive behavior, leading the student to quit the team and report the incident to his father. The parent, dissatisfied with the teacher's conduct, began raising concerns about the teacher's alleged inappropriate behavior, including claims of physical and verbal abuse, to school administrators and at a school board meeting. The parent also communicated these concerns to the school superintendent and, according to the teacher, made a report to local police. Investigations by both the police and the Division of Child and Family Services found no evidence of abuse, and the teacher was ultimately terminated without a stated reason.The teacher filed suit in the Third District Court, Salt Lake County, alleging defamation, intentional infliction of emotional distress (IIED), abuse of process, and tortious interference with economic relations. The parent moved for early dismissal under Utah’s Uniform Public Expression Protection Act (UPEPA), arguing the statute protected his speech and actions. The district court denied the motion, finding UPEPA inapplicable and concluding that the teacher had stated prima facie cases for all claims.On direct appeal, the Supreme Court of the State of Utah held that the district court erred in finding UPEPA did not apply, as the parent’s statements concerned a matter of public concern. The Supreme Court also found that the teacher failed to state prima facie cases for IIED and abuse of process, requiring dismissal of those claims. The court vacated the denial of the special motion as to defamation and tortious interference, remanding for further consideration of whether the teacher could establish a prima facie case, particularly regarding privilege. The court ordered costs and fees related to the motion be awarded as provided by UPEPA. View "Mackey v. Krause" on Justia Law

Two individuals who were active in efforts to incorporate the community of Erda, Utah, alleged that three other residents defamed them and placed them in a false light. The plaintiffs had been involved in organizing the incorporation, including gathering signatures and working with property owners. After the incorporation was approved by voters, a local ranch company filed lawsuits alleging fraud in the incorporation process, specifically that signatures had been misused or altered. The defendants, in various public forums and on social media, accused the plaintiffs of fraud, forgery, and other misconduct related to the incorporation and subsequent community disputes.The Third District Court in Tooele County dismissed the plaintiffs’ claims. It found that the statements made by two defendants were not capable of defamatory meaning, were privileged, and that the false light claims failed for the same reasons. For the third defendant, the court granted judgment on the pleadings under Utah’s Anti-SLAPP Act, concluding that his statements were protected as participation in the process of government and that the lawsuit was intended to chill such participation.The Supreme Court of the State of Utah reversed and remanded. It held that at least some of the statements by the first two defendants were capable of defamatory meaning and were not constitutionally protected opinions. The court also held that it was improper to dismiss the claims on privilege grounds at the motion to dismiss stage, as privilege is an affirmative defense that must be raised and supported by the defendant. Regarding the third defendant, the court held that the Anti-SLAPP Act did not apply because his statements were not made while participating in the process of government as defined by the statute. The court ordered that the case proceed on all claims. View "Mathews v. McCown" on Justia Law

After experiencing shortness of breath and chest pain, Jorge Armenta lost consciousness and his wife called 911. Emergency medical technicians from Unified Fire Authority (UFA) responded, evaluated Armenta, and told him that everything appeared normal, suggesting he had an anxiety attack and did not need to go to the emergency room. A week later, Armenta was hospitalized for a massive heart attack, which resulted in significant and potentially life-shortening heart damage. Armenta filed a negligence suit against UFA, alleging that their failure to properly diagnose and treat him caused his injuries.The Third District Court, Salt Lake County, reviewed UFA’s motion to dismiss, which argued that the Utah Governmental Immunity Act (UGIA) shielded UFA from liability. The district court applied a three-part test, found that UFA’s actions were a governmental function, that immunity was generally waived for such activities, but that an exception for “providing emergency medical assistance” restored immunity. The court dismissed Armenta’s claims against UFA and entered judgment under rule 54(b) of the Utah Rules of Civil Procedure.On direct appeal, the Supreme Court of the State of Utah reviewed the district court’s statutory interpretation and dismissal. The Supreme Court held that the district court erred in its interpretation of the “providing emergency medical assistance” exception under the UGIA. The Court determined that, when read in context with related statutory provisions, the exception applies only to medical assistance provided in response to certain types of emergencies, such as disasters or catastrophic events, not to routine emergency medical responses like the one at issue. Therefore, the UGIA does not immunize UFA from Armenta’s suit. The Supreme Court reversed the district court’s dismissal and remanded the case for further proceedings. View "ARMENTA v. UNIFIED FIRE AUTHORITY" on Justia Law

A four-year-old child suffered severe brain damage due to a massive air embolism during surgery in July 2018. The child's parents, John and Amelia Tullis, sued the healthcare providers, including the University of Utah, in 2019, alleging negligence and seeking damages for pain, anguish, and future medical expenses estimated to exceed $22 million.The University of Utah sought to limit the potential recovery by invoking the 2017 Governmental Immunity Act of Utah (GIA), which capped damages at $745,200. The Third District Court of Salt Lake County denied the University's motion for partial summary judgment, reasoning that the decision in Condemarin v. University Hospital, which found a different damages cap unconstitutional as applied to University Hospital, necessarily determined that the 2017 GIA’s damages cap was also unconstitutional as applied to the University.The Utah Supreme Court reviewed the case to determine whether Condemarin controlled the current issue. The court concluded that Condemarin, a plurality decision with a narrow holding, did not control the case. The court noted that Condemarin’s holding was limited to the specific statutes at issue in that case, which imposed a $100,000 cap, whereas the 2017 GIA set a higher limit and included a mechanism for adjusting for inflation. The court emphasized that Condemarin’s holding did not automatically apply to the revised statute with different terms.The Utah Supreme Court reversed the district court’s decision and remanded the case for further proceedings, noting that the district court should consider the Tullises' request for discovery on the applicability of the damages cap. View "University of Utah Hospital v. Tullis" on Justia Law

Randi Mariani crashed her motor scooter and sustained a serious injury during a driving skills test, which she was taking to obtain a motorcycle endorsement to her driver license. Following the crash, the Utah Department of Public Safety-Driver License Division (DLD) denied Mariani’s application for the endorsement. Mariani sued the DLD for negligently causing her injury. The district court granted summary judgment to the DLD based on governmental immunity, and the court of appeals affirmed.The district court concluded that the DLD was immune from Mariani’s suit under the Governmental Immunity Act of Utah (GIA), reasoning that Mariani’s injury arose out of the administration of her motorcycle skills test, which was part of the licensing process. The court of appeals agreed, stating that Mariani’s injury was at least incident to the licensing approval process.The Utah Supreme Court reviewed the case to determine whether the court of appeals erred in affirming the district court’s decision. The Supreme Court focused on the specific language of the GIA’s licensing exception, which provides immunity for injuries that arise out of or in connection with the denial of a license. The Court concluded that the relevant conduct was the denial of the motorcycle endorsement, not the licensing process itself. The Court further determined that there was no causal relationship between the denial of the license and Mariani’s injury, as the injury occurred before the denial. Therefore, the licensing exception did not apply, and the DLD was not immune from Mariani’s suit. The Supreme Court reversed the court of appeals’ decision and remanded the case for further proceedings. View "Mariani v. Driver License Division" on Justia Law

In this case, Tiffany Bingham challenged the constitutionality of the Utah Health Care Malpractice Act’s four-year statute of repose after her medical malpractice claim against Dr. George C. Gourley and Dr. McKay L. Platt was dismissed. Bingham underwent surgeries in 2010, experienced complications, and discovered in 2017 that the surgeries had caused damage, leading to the removal of her kidney. She filed her lawsuit in 2020, more than four years after the alleged malpractice, prompting the dismissal of her claim under the statute of repose.The Fourth District Court in Provo dismissed Bingham’s complaint, concluding that the statute of repose was constitutional. The court found that the statute did not violate the Open Courts Clause, the Uniform Operation of Laws Provision, or the Equal Protection Clause. The court reasoned that the statute was a non-arbitrary means of addressing the social and economic issues related to rising medical malpractice insurance costs and was reasonably necessary to achieve the legislative goal of stabilizing insurance premiums.The Utah Supreme Court affirmed the lower court’s decision. The court held that Bingham failed to demonstrate that the statute of repose violated the Open Courts Clause, as the legislature’s findings of a health care crisis were fairly debatable and the statute was a reasonable means to address that crisis. The court also found that the statute did not violate the Uniform Operation of Laws Provision, as it was reasonably necessary to achieve the legislative goals and actually and substantially furthered those goals. Finally, the court concluded that the statute did not violate the Equal Protection Clause, as it was rationally related to a legitimate public purpose and did not impair a fundamental right. View "Bingham v. Gourley" on Justia Law

A plaintiff filed a lawsuit against a defendant, alleging that the defendant's negligence caused a car accident resulting in significant injuries. The plaintiff claimed that the defendant ran a red light and collided with the plaintiff's vehicle. The defendant denied the allegations, arguing that the light was green and that the plaintiff was at fault for the accident.The trial court, a state district court, heard the case and the jury found in favor of the plaintiff, awarding substantial damages. The defendant appealed the decision to the state court of appeals, arguing that the trial court made several errors, including improper jury instructions and the exclusion of certain evidence that could have supported the defendant's case.The state court of appeals reviewed the case and upheld the trial court's decision, finding that the jury instructions were appropriate and that the exclusion of evidence did not prejudice the defendant's case. The defendant then appealed to the state's highest court, the State Supreme Court, seeking further review.The State Supreme Court affirmed the lower courts' decisions, holding that the trial court did not abuse its discretion in its jury instructions or in its evidentiary rulings. The court emphasized that the jury's verdict was supported by substantial evidence and that the trial court's actions were within the bounds of its discretion. The Supreme Court's decision effectively ended the defendant's appeals, leaving the jury's award to the plaintiff intact. View "State v. Chadwick" on Justia Law