Justia Utah Supreme Court Opinion Summaries

Husband and Wife divorced in 2005. During the pendency of the divorce proceedings, Wife brought a separate civil suit seeking various forms of equitable relief and monetary damages, which the district court granted. At issue in the civil suit was certain property on which the couple ran an equestrian business but which a Husband's corporation owned. Husband filed a timely notice of appeal, arguing, inter alia, that the district court erroneously found that an express oral agreement existed between Husband and Wife to purchase, hold, and develop the property, and the equestrian business therein, for their mutual enjoyment and benefit. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err in imposing a constructive trust and declaring the property part of the marital estate; but (2) the district court erred in its determination that an enforceable agreement existed, as the purported agreement lacked sufficient specificity. Remanded. View "Goggin v. Goggin" on Justia Law

This case concerned a dispute over a parcel of land situated between adjoining landowners, Defendant and Plaintiff. Plaintiff was the record owner of the property, but Defendant and its predecessors-in-interest occupied the properly for approximately fifty years. The district court quieted title to the property in favor of Defendants after finding that the parties' predecessors-in-interest mutually acquiesced to a boundary marked by an old barbed wire fence. The Supreme Court affirmed, holding (1) the standard of proof in boundary by acquiescence cases is clear and convincing evidence; (2) acquiescence does not require any degree of subjective intent; and (3) Defendant's predecessors-in-interest acquiesced to the original barbed wire fence as the boundary between the properties. View "Essential Botanical v. Kay" on Justia Law

David and Kristine Anderson purchased an undeveloped lot of land from Country Living Development. After constructing a home on the lot, the Andersons' home developed structural problems resulting from excessive settling caused by unstable soil beneath their home's foundation. The Andersons filed suit against Matthew Kriser, an employee and shareholder of Country Living, for fraudulent nondisclosure. The district court granted summary judgment in favor of Kriser. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the court of appeals correctly concluded that a plaintiff must demonstrate that a defendant had actual knowledge of undisclosed information to satisfy the elements of a claim for fraudulent disclosure; (2) because the Andersons failed to set forth any evidence demonstrating that Kriser actually knew of the soil conditions below their home, summary judgment was proper; and (3) the court of appeals erred in relying on the Court's holding in Smith v. Frandsen to reach its conclusion that the law imposed no duty on Kriser to disclose information to the Andersons simply because he did not construct their home. View "Anderson v. Kriser" on Justia Law

The Utah Department of Transportation (UDOT) condemned real property belonging to Admiral Beverage Corporation, and Admiral was entitled to compensation from the State for the taking of its property. During the condemnation proceedings, Admiral sought to introduce evidence of the fair market value of its property, including evidence of its damages arising from the loss of view and visibility of its remaining property. The district court ruled that evidence of the fair market value of Admiral's property was not admissible under the holding in Ivers v. UDOT. The court of appeals affirmed. The Supreme Court reversed, holding (1) the part of Ivers that allowed severance damages only for "recognized property rights" was too restrictive to accord the full protection of the Utah Constitution, was inconsistent with both Utah statutes and the Court's prior case law, and was therefore overruled; and (2) Admiral had the right to recover from UDOT for the decrease in the fair market value of its remaining property resulting from the condemnation. View "Utah Dep't of Transp. v. Admiral Beverage Corp." on Justia Law

L.C. Canyon filed an application with Salt Lake County to rezone several acres of its property to allow the construction of a residence on the property. The County Planning Commission recommended its approval to the Salt Lake County Council. The Council then passed an ordinance amending the zoning map to grant L.C. Canyon's requested rezoning. Before the ordinance was to take effect, the Council rescinded the rezoning ordinance. L.C. Canyon filed a complaint against the County, asserting that the Council had no authority to rescind the rezoning ordinance and that the rescission effected a taking of L.C. Canyon's property. The district court entered summary judgment against L.C. Canyon. The Supreme Court affirmed, holding (1) the County had a rational basis for its zoning decision, (2) the Council had the authority to rescind its rezoning ordinance before it became effective, and (3) because L.C. Canyon had only a unilateral hope that the rezoning ordinance ultimately would take effect, it had no viable takings claim. View "L.C. Canyon Partners v. Salt Lake County" 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

Appellants, Marion Energy and the State of Utah School and Institutional Trust Lands Administration, leased and owned oil and gas deposits lying underneath property owned by the KFJ Ranch Partnership. In order to build a road to access those deposits, Appellants sought to condemn a portion of KFJ's land by relying upon a statute that permits the exercise of eminent domain for the construction of roads to facilitate the working of mineral deposits. The district court dismissed Appellants' condemnation action, concluding that the statute did not provide the authority to take land for roads to access oil and gas deposits. The Supreme Court affirmed the district court's dismissal, holding that the phrase "mineral deposits" in the statute was ambiguous, and because all ambiguities in a statute purporting to grant the power of eminent domain are strictly construed against the condemning party, Appellants were not authorized by the statute to condemn KFJ's land. View "Marion Energy, Inc. v. KFJ Ranch P'ship" on Justia Law

Sanpete America purchased 110 acres of farmland and water rights from Christian Willardsen pursuant to a land purchase agreement and a warranty deed. After discovering problems with respect to the conveyance of the water right at issue, Sanpete America filed a complaint against Willardsen and Douglas Neeley, Willardsen's attorney, asserting various causes of action and seeking damages. Two successive district court judges issued judgments dismissing Sanpete America's claims against Willardsen and Neeley. On appeal, the Supreme Court affirmed both judges' conclusion that Sanpete America was entitled to no damages and judgment dismissing Sanpete America's claims, holding (1) Willardsen conveyed his portion of the water right to Sanpete America under a warranty deed, (2) Willardsen breached no covenants in the deed, and (3) Neeley's actions were not the cause of Sanpete America's alleged damages. View "Sanpete America, L.L.C. v. Willardsen" on Justia Law

This case concerned the application of payments made in connection with a real estate transaction between Kang Park and Marsha Park and Gary Stanford. The district court granted summary judgment to the Parks, determining, as a matter of law, that none of the payments Stanford submitted to the Parks could be credited toward a personal guaranty Stanford had made on the note payable to the Parks. The court of appeals affirmed the district court's grant of summary judgment, concluding that no evidence indicated the Parks had actual knowledge that Stanford intended for the past payments to apply to his guaranty and no agreement or contractual provision expressly required the Parks to make such an application. On certiorari, the Supreme Court reversed, holding (1) the court of appeals applied the wrong test in its holding, and rather, a rule in which payments are credited toward a personal guaranty when the recipient of the payments has a reasonable basis to know the payments were submitted in satisfaction of the guaranty governed the application of payments toward a personal guaranty; and (2) genuine issues of material fact precluded summary judgment under the rule and the record required further development. Remanded. View "Park v. Stanford" on Justia Law

Barbara and Steven Selvig, as sellers, and Blockbuster Enterprises, as buyer, entered into a real estate purchase contract for the purchase of a bed and breakfast. The contract specified that the deed to the property would be recorded when Blockbuster paid the full purchase price. Before paying the full purchase price, however, Blockbuster recorded the deed. The sellers sued in district court on several theories of liability. The district court granted Blockbuster's motion to dismiss, dismissing (1) the seller's claims for breach of contract and breach of the covenant of good faith and fair dealing, holding that the sellers had elected their remedy pursuant to an election of remedies provision in the contract by keeping the earnest money deposit; and (2) the seller's unjust enrichment claim. The Supreme Court affirmed in part and reversed in part, holding (1) the district court erred in dismissing the seller's contractual claims because the election of remedies provision does not apply to a breach of contract claim out of a wrongful recording of the deed; and (2) the district court correctly dismissed the seller's claim for unjust enrichment because the sale of the property was covered by a written contract. View "Selvig v. Blockbuster Enterprises, L.C." on Justia Law