Justia Utah Supreme Court Opinion Summaries

Nicholas and Julie Kuhar filed a product liability claim against Thompson Manufacturing, a Utah company, seeking compensation for injuries Nicholas sustained when his safety harness failed while he was cleaning rain gutters in New Jersey. This was not the first lawsuit the Kuhars had brought regarding this incident. They had previously sued Thompson and other defendants in New Jersey federal court, alleging that the harness was defective. That suit was unsuccessful, with Thompson being dismissed from the case due to a lack of personal jurisdiction. The Kuhars then refiled their claims against Thompson in Utah.In the New Jersey case, the Kuhars' expert witness was excluded, and the remaining defendants were granted summary judgment. Thompson then moved in the Utah case to preclude the Kuhars from litigating the issue of whether the harness was defective. The district court agreed with Thompson and dismissed the Kuhars' claims. However, the Utah Court of Appeals reversed this decision, concluding that the issue litigated and decided in New Jersey was not identical to the issue Thompson sought to preclude in Utah.The Supreme Court of the State of Utah, however, disagreed with the Court of Appeals. It concluded that the elements of issue preclusion were satisfied. The court clarified that to determine the issue-preclusive effect of the New Jersey federal court’s judgment in this case, the substantive law of New Jersey applies. Under that law, the court concluded that the issue Thompson sought to preclude the Kuhars from litigating—whether the harness was defective—was actually litigated and decided on the merits in the New Jersey court’s summary judgment order. Therefore, the Supreme Court of the State of Utah reversed the decision of the Court of Appeals. View "Kuhar v. Thompson Manufacturing" on Justia Law

In the medical malpractice case concerning the withdrawal of life-sustaining treatment from Lillian Birt, her daughter Jenafer Meeks sued the treating doctors, Wei Peng and Christina G. Richards, both individually and on behalf of Ms. Birt's heirs and estate. The children of Ms. Birt had decided to discontinue her life support based on the misinformation they received from the doctors about her condition. The doctors inaccurately portrayed her condition as terminal, leading the children to believe that the treatment was only prolonging her life unnaturally. However, Ms. Birt's condition was not terminal, and there was a high probability of her recovery if the treatment had continued.In the Supreme Court of the State of Utah, the doctors appealed on two issues. Firstly, they argued that the trial court's jury instruction 23 was incorrect as it did not explicitly state that Ms. Meeks had the burden to prove the standard of care. Secondly, they contended that the lower court erred in denying their motion for judgment as a matter of law on the survival claim due to lack of evidence that Ms. Birt experienced pain and suffering in the hours between the doctors' negligence and her death.The Supreme Court held that the trial court correctly instructed the jury that Ms. Meeks had the burden to prove the standard of care, as the instruction implicitly required the jury to determine the standard of care as part of proving a breach of it. However, the Supreme Court agreed with the doctors that Ms. Meeks failed to provide evidence of Ms. Birt's experience of pain, suffering, or inconvenience during the period between the doctors' negligence and her death. Therefore, the Supreme Court affirmed in part and reversed in part the decision of the lower court. View "Peng v. Meeks" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Robyn Young's motion to dismiss this action brought by Granite School District regarding settlement proceeds Young had received for industrial injuries, holding that the Labor Commission had exclusive jurisdiction over the factual questions at the heart of this reimbursement dispute.Young, a special education teacher, sought workers' compensation for injuries she received at the hands of her students. An administrative law judge awarded Young benefits, finding that Young was permanently and totally disabled and that Young did not have to reimburse Granite with funds she received from a legal settlement she had obtained against medical debt collectors for violations of the Fair Debt Collection Practices Act. Granite then initiated suit for reimbursement from Young under the Utah Workers' Compensation Act. The district court granted Young's motion to dismiss. The Supreme Court affirmed, holding that the district court did not err when it dismissed Granite's complaint because the Workers' Compensation Act assigned the Commission exclusive jurisdiction over this dispute. View "Granite School District v. Young" on Justia Law

The Supreme Court affirmed the judgment for Defendants on Plaintiffs' respondeat superior-related claims, holding that the district court correctly held that respondeat superior principles did not make the remaining defendants in this case vicariously responsible for the abuse committed by a physician assistant and that the Utah Physician Assistant Act did not change that conclusion.Plaintiff brought an action against Alta Pain Physicians; Oscar Johnson, a physician assistant; and Dr. Michael Chen, Johnson's supervising physician, alleging that Johnson subjected her to sexual harassment and abuse when she saw him for pain treatment at Alta Pain. After Plaintiff settled her claims against Johnson the district court granted the motion for summary judgment filed by Chen and Alta Pain on Plaintiff's claims of sexual assault, sexual battery, and intentional infliction of emotional distress. The Supreme Court affirmed, holding (1) the district court did not err in entering summary judgment on Plaintiff's respondeat superior-based claims; and (2) Plaintiff did not met her burden of convincing the Court to overturn precedent and use a foreseeability test for plaintiffs to recover against employers of abusive employees. View "Burton v. Chen" on Justia Law

On interlocutory appeal, the Supreme Court reversed the judgment of the district court denying partial summary judgment in favor of the Estate of Miguel Huitron in the underlying tort action, holding that the Estate was entitled to a partial summary judgment order.Plaintiff, the only survivor of a crash caused by Huitron, filed a personal injury lawsuit against the Estate approximately three years after the accident, claiming total damages in the millions. The Estate moved for partial summary judgment, which the district court denied. The Supreme Court reversed, holding that several issues could be decided as a matter of law at the summary judgment stage. The Court remanded the case to the district court to continue the proceedings consistent with this opinion. View "Estate of Huitron v. Kaye" on Justia Law

The Supreme Court reversed in part and affirmed in part the judgment of the district court granting Volkswagen SouthTowne's motion for judgment as a matter of law and a new trial after Plaintiff was awarded $2,700,000 on her negligence and strict liability claims, holding that SouthTowne was not entitled to judgment as a matter of law or a new trial.SouthTowne sold Plaintiff a vehicle that was subject to a safety recall because of defective fuel injection lines. After buying the car, Plaintiff was diagnosed with carbon monoxide poisoning. A mechanic discovered that the safety recall had not been performed on Plaintiff's vehicle. A jury returned a verdict in favor of Plaintiff, but the district court entered post-trial orders concluding that Plaintiff had failed sufficiently to establish the applicable standard of care. The Supreme Court reversed in part, holding (1) the cumulative evidence adduced at trial was legally sufficient to satisfy the element of causation; and (2) the trial court erred in basing its ruling conditionally granting a new trial to SouthTowne because the ruling was based on issues that Plaintiff was not given notice and an opportunity to be heard on. View "Smith v. Volkswagen Southtowne, Inc." on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment in favor of Weber County and dismissing the claims brought by Brian and Mariah Cunningham against the County, a Special Weapons and Tactics training provider, holding that the district court erred across the board.Brian was attending a training when can explosive set on a door latch detonated and caused severe injuries to Brian's face and neck. Brian and Mariah sued the County, alleging negligence and gross negligence. The district court granted the County's motion for summary judgment. The Supreme Court reversed and remanded the action, holding (1) the preinjury release Brian signed was unenforceable because it was neither clear nor unmistakable; and (2) the Governmental Immunity Act of Utah waives immunity for gross negligence claims and loss of consortium claims that arise out of an injury for which immunity has been waived. View "Cunningham v. Weber County" on Justia Law

The Supreme Court vacated the decision of the district court denying the motion for summary judgment filed by Barnes Bullets asking the district court to rule that the Workers' Compensation Act (WCA) barred Layne Kay's claim, holding that the Occupational Disease Act (ODA) may bar Kay's lawsuit.Kay contracted lead poisoning while working at Barnes and sued Barnes under the exception to the WCA permitting employees like Kay to sue over injuries caused by an employer's intentional act. Barnes moved for summary judgment, arguing that the WCA barred Kay's claim where Kay did not present sufficient evidence that Barnes acted intentionally. The Supreme Court vacated the district court's decision and remanded the case for further proceedings, holding that Utah law recognizing lead poisoning as an occupational disease raises a significant question as to whether the ODA, not the WCA, covered Kay's claim. View "Kay v. Barnes Bullets" on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment to Steven DeConto and Commodity Transporters, Inc. and dismissing John Zilleruelo's complaint alleging negligence, vicarious liability, and negligent entrustment, holding that the district court misinterpreted Utah Code 78B-2-108(2).While Zilleruelo filed his complaint outside the statute of limitations he argued that the accident had rendered him mentally incompetent for one year, and therefore, section 78B-2-108(2) tolled the statute of limitations during the period of his incompetency. The district court granted summary judgment for the defendants, concluding that the statute of limitations had continued to run during the time Zilleruelo claimed he was incompetent. The Supreme Court reversed, holding that the tolling statute does not condition tolling on the lack of a power of attorney or the lack of a legal guardian. View "Zilleruelo v. Commodity Transporters, Inc." on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment to two job site operators during the 1960s and 1970s for indirectly exposing his wife to asbestos dust, holding that job site operators owe a duty of care to a worker's cohabitants with respect to take-home exposure to asbestos.During his marriage to Barbara Boynton, Larry Boynton worked at numerous job sites where he was exposed to asbestos. Larry alleged in this complaint that Barbara was exposed to asbestos dust he carried home from work, bringing on her mesothelioma and resulting death. The district court granted summary judgment for two job site operators, concluding that they did not owe a duty of care to Barbara. The Supreme Court reversed, holding (1) job site operators are liable to their employees' cohabitants for take-home asbestos exposure; and (2) a genuine issue of material fact existed about whether one of the operators retained control over its contractor. View "Kennecott Utah Copper, LLC v. Phillips 66 Co." on Justia Law