Justia Utah Supreme Court Opinion Summaries

A nonprofit entity, Sports Medicine Research and Testing Laboratory (Sports Medicine), sought a property tax exemption for its South Jordan facility, claiming it was used exclusively for charitable purposes. Sports Medicine performs testing for both professional sports organizations at market rates and for government agencies and charitable organizations at discounted or no cost. It argued that the revenue from market-rate testing supports its charitable mission and that its vacant property space is intended for future charitable use.The Salt Lake County Board of Equalization denied the exemption, stating the property was not used exclusively for charitable purposes. Sports Medicine appealed to the Utah State Tax Commission, which affirmed the Board's decision. Sports Medicine then sought judicial review from the Utah Supreme Court.The Utah Supreme Court held that the property did not qualify for a tax exemption. The court reasoned that while Sports Medicine's discounted testing for charitable organizations could be considered a charitable use, its market-rate testing for professional sports organizations was not. The court emphasized that generating profit, even if used to support a charitable mission, does not constitute a charitable use of property. Additionally, the court found that the vacant portion of the property, intended for future charitable use, did not meet the requirement for current exclusive charitable use. Consequently, the court upheld the Tax Commission's denial of the property tax exemption. View "Sports Medicine Research v. Tax Commission" on Justia Law

Brett Del Valle was sued by Alum Rock Riverside, LLC in California for breach of contract, resulting in a judgment against him for over $4 million. Alum Rock domesticated this judgment in Utah and recorded it with the Weber County Recorder’s Office. At the time of recording, the property in question was held by a revocable trust established by Brett and his wife, but the trust sold the property to the Mulligans before Alum Rock applied for a writ of execution to seize and sell the property.The Third District Court upheld the writ of execution despite the Mulligans' objections. They argued that Alum Rock failed to create a valid judgment lien because it did not record the judgment in the registry of judgments, that the writ was not available since the trust held the title when the judgment was domesticated, and that the court lacked jurisdiction as the property was in a different judicial district. The district court rejected these arguments, holding that recording the judgment with the county recorder was sufficient to create a lien, the writ was valid because Brett retained ownership indicia over the property, and the court had jurisdiction to issue the writ.The Utah Supreme Court affirmed the district court’s decision. It held that since July 1, 2002, a judgment lien is created by recording the judgment with the county recorder, not by filing it in the registry of judgments. The court also determined that Brett owned the property for purposes of the lien because he retained control over the trust. Finally, the court found no relevant limitation on the district court’s jurisdiction to issue the writ, even though the property was located in a different judicial district. View "Mulligan v. Alum Rock Riverside" on Justia Law

Lippa and Manmohan Grewal sold a gas station to Theodore Hansen, who later sold it to Junction Market Fairview, L.C. (JMF). The sale contract required Hansen to make regular installment payments, with the final balance due after three years. Hansen missed many payments and failed to pay the full balance when due. The Grewals initiated foreclosure proceedings over six years after Hansen's first missed payment. The applicable statute of limitations for a breach of contract action is six years, raising the question of when the statute begins to run for installment contracts.The Sixth District Court in Sanpete County granted partial summary judgment in favor of JMF, concluding that the statute of limitations began when Hansen missed the first payment, making the Grewals' foreclosure action too late. The court awarded sole control of the gas station to JMF and ordered the Grewals to release the title. When the Grewals failed to comply, JMF seized the station and sold it to a third party. The district court also awarded JMF attorney fees under the Public Waters Access Act and the reciprocal attorney fees statute.The Utah Supreme Court reviewed the case and found that the sale of the gas station to a third-party bona fide purchaser rendered the Grewals' appeal on the title issue moot, as no court action could affect the litigants' rights to the property. However, the issue of attorney fees was not moot. The court held that the district court did not abuse its discretion in awarding attorney fees to JMF under the reciprocal attorney fees statute. The court affirmed the award of attorney fees and remanded to the district court to determine the amount of reasonable attorney fees JMF incurred in defending against the appeal. View "Grewal v. Junction Market Fairview" on Justia Law

Weston Bennion was injured when his apartment deck collapsed and subsequently sued his landlord, Dale Stolrow, for negligence. The parties settled, with Bennion agreeing to release Stolrow and his insurer from all claims in exchange for $150,000. The settlement was subject to related subrogation claims and healthcare liens, and Bennion promised to indemnify Stolrow from liability for any such claims and liens. Before making the payment, Stolrow informed Bennion that he intended to distribute the payment in two checks: one payable to Bennion and the other payable to a collection agency that had a healthcare lien on the settlement funds. Bennion objected and filed a motion to enforce the parties’ agreement, arguing that its terms did not allow Stolrow to issue a portion of the settlement funds to a third party.The district court disagreed with Bennion and suggested that Stolrow issue two checks: one jointly to Bennion and the third party for the amount of the lien, and another to Bennion for the remainder of the funds. The court of appeals affirmed the district court’s decision. Bennion then petitioned for certiorari.The Supreme Court of the State of Utah granted certiorari to address whether the court of appeals erred in concluding that the parties’ agreement permitted Stolrow to issue a portion of the settlement funds jointly to Bennion and the third-party collection agency. The court agreed with Bennion, stating that the plain language of the release provides for payment to Bennion in exchange for his release of claims against Stolrow and his assumption of responsibility for third-party liens. Therefore, the court reversed the decision of the lower courts. View "Bennion v. Stolrow" on Justia Law

A dispute arose between SunStone Realty Partners X LLC (SunStone) and Bodell Construction Company (Bodell) over the postjudgment interest rate applied to a domesticated Hawaii judgment in Utah. Following arbitration in Hawaii over construction defects in a condominium development, SunStone obtained a judgment against Bodell exceeding $9.5 million, which it domesticated in Utah. Bodell requested the Utah court to apply Utah's lower postjudgment interest rate instead of Hawaii's higher one. SunStone opposed this, arguing that the Utah Foreign Judgment Act (UFJA) required the application of Hawaii's rate, or alternatively, that their contract or principles of comity mandated the Hawaii rate.The Supreme Court of the State of Utah affirmed the district court's decision to apply Utah's postjudgment interest rate. The court found that the UFJA, which does not specifically address postjudgment interest, instructs Utah courts to treat a foreign domesticated judgment like a Utah judgment for enforcement purposes. Since postjudgment interest serves, at least in part, as an enforcement mechanism, the UFJA requires the imposition of Utah’s postjudgment interest rate. Further, the construction contract did not require the application of the Hawaii postjudgment interest rate. The court did not consider principles of comity because the UFJA mandates a result. View "Sunstone Realty v. Bodell Construction" on Justia Law

The Supreme Court affirmed the determination of the Utah State Tax Commission that the Property Tax Division correctly followed the requirements of the Aircraft Valuation Law, Utah Code 59-2-201 subsection 4, in determining the 2017 value of Delta Air Lines' aircraft, holding that Salt Lake County failed to demonstrate that the Law, as applied to Delta's 2017 assessment, violated the fair market value provision of the Utah Constitution.For tax year 2017, the Division valued Delta's aircraft according to section 59-2-201's preferred methodology. The County appealed, arguing that the valuation did not reflect the fair market value of Delta's aircraft, in violation of the Utah Constitution. The Commission upheld the assessment, concluding that the County did not establish that the Legislature's preferred method of valuation did not reasonably reflect fair market value. The Supreme Court affirmed, holding that the Aircraft Valuation Law was not unconstitutional as applied by the Commission to assess the value of Delta's aircraft for tax year 2017. View "Salt Lake County v. Utah State Tax Commission" on Justia Law

The Supreme Court affirmed the judgment of the district court partially granting summary judgment concluding that a homeowners association (HOA) was entitled to collect past due assessments against Robbie Frank, the trustee of two trusts that each owned a lot within the HOA's boundaries, but that a bench trial was necessary to determine the amount owing, holding that the district court did not err.On appeal, Frank argued (1) the documents establishing the HOA were void as against public policy and that void documents cannot be ratified, and (2) in the alternative, the district court erred in determining that ratification had occurred in this case. The Supreme Court affirmed, holding (1) the governing documents were merely voidable, not absolutely void; and (2) the district court did not err in determining that the HOA had authority to assess the properties because the HOA members collectively ratified the HOA's authority. View "Hi-Country Estates Homeowners Ass'n, Phase II v. Frank" on Justia Law

In this action brought by Utah Stream Access Coalition (USAC) after USAC members were cited for trespass for wading in the Provo River on property owned by VR Acquisitions the Supreme Court held that the district court correctly entered judgment against USAC.In its complaint, USAC claimed that the Public Waters Access Act (PWAA) violated Utah Const. art. XVII and XX and federal common law. The district court entered summary judgment against USAC on its article XVII and federal common law claims but, after a bench trial, determined that the PWAA violated article XX. On appeal, the Supreme Court determined that the district court made a threshold error in reaching its article XX determination and remanded with instruction that the court address the threshold question of whether the easement identified in Conaster v. Johnson, 194 P.3d 897 (Utah 2008), had a historical basis as a public easement at the time the Utah Constitution was framed. On remand, the district court granted summary judgment for VR Acquisitions and the State. The Supreme Court affirmed, holding that because USAC did not identify an affirmative, 19th-century legal basis for a Conaster easement, the district court correctly ruled that USAC did not make the threshold showing. View "Utah Stream Access Coalition v. VR Acquisitions, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court in favor of a homeowners' association in this dispute against Owner over unpaid assessments concluding that the HOA was entitled to collect the assessments because the HOA members in general had ratified the HOA's authority, holding that protective covenants that were not signed by the property owner are capable of ratification.The HOA in this case sued the Owner of a lot within its boundaries for unpaid assessments. The Owner argued, in response, that the HOA's governing documents were unauthorized encumbrances on the lot and therefore violated the Wrongful Lien Act. The district court granted summary for the HOA. The Supreme Court affirmed, holding (1) protective covenants that were not signed by the property owner are voidable but not void as against public policy and are thus capable of ratification; (2) the district court correctly ruled that the HOA at the authority to assess the lot at issue and correctly calculated the unpaid assessments owing to the HOA; and (3) the HOA was entitled to its attorney fees on appeal. View "Hi-Country Estates v. MountainTop Properties" on Justia Law

The Supreme Court affirmed the decision of the Utah State Tax Commission agreeing with the determination of Washington County that rental property owned by Durbano Properties, LC in the County did not qualify for a property tax exemption, holding that Durbano was not entitled to relief on its claims of error.For the 2010 through 2017 tax years Durbano received a residential tax exemption as provided by the Property Tax Act, Utah Code 59-2-103(3), under which property owners are allowed an exemption equal to forty-five percent of the fair market value of "property used for residential purposes as a primary residence," Utah Code 59-2-102(34)(a). Durbano brought a petition arguing that limiting the residential exemption to property used as a primary residence violated the permissive authority granted to the legislature. The Supreme Court disagreed and declined to disturb the Commission's decision, holding that Durbano provided no legal basis to invalidate the legislature's definition of "residential property" as authorized by Utah Const. art. XIII, 3. View "Durbano Properties, LC v. Utah Tax Comm'n" on Justia Law