Justia Utah Supreme Court Opinion Summaries

David Pyper hired attorney Justin Bond to represent him in a probate matter. Bond's law firm subsequently sued Pyper to obtain payment of the attorney fees. The district court entered a judgment in favor of the law firm for $10,577. To satisfy the judgment, Bond filed a lien against a house owned by Pyper that was worth approximately $125,000. Bond was the only bidder at the sheriff's sale auctioning Pyper's home and purchased Pyper's home for $329. Pyper later communicated his desire to redeem his property to Dale Dorius, another attorney at the firm, but was unable to speak to Bond after several attempts. After the redemption period expired, the deed to Pyper's home was transferred to Bond. Pyper subsequently filed a petition seeking to set aside the sheriff's sale of his property. The district court set aside the sheriff's sale. The court of appeals affirmed. The Supreme Court affirmed, holding the court of appeals did not err in (1) concluding that gross inadequacy of price together with slight circumstances of unfairness may justify setting aside a sheriff's sale and (2) affirming the district court's conclusion that Bond and Dorius's conduct created, at least, slight circumstances of unfairness. View "Pyper v. Bond" 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

Chanzy Walker was involved in an accident that killed one person. The detectives investigating the incident obtained a warrant from a magistrate judge to draw and test Walker's blood. A blood sample from Walker revealed the presence of methamphetamine and amphetamine. After the State charged Walker with several offenses, Walker filed a motion to suppress the results of the blood test. At a pretrial hearing, The district court concluded that the warrant lacked probable cause. Despite this conclusion, the district court denied the motion to suppress based on its determination that the good faith exception to the exclusionary rule applied in this case. Walker later entered a conditional plea to causing the death of another by operating a motor vehicle in a negligent matter with a controlled substance in the body and possessing a controlled substance. The Supreme Court affirmed the district court's denial of Walker's motion to suppress, holding that the magistrate had a substantial basis to believe that evidence of illegal conduct would be found in Walker's blood and, therefore, the warrant was supported by probable cause. View "State v. Walker" on Justia Law

Douglas Lovell pleaded guilty to aggravated murder. Lovell subsequently moved to withdraw his plea. The district court initially held that Lovell's motion was untimely, but the Supreme Court reversed and remanded for consideration of the merits of Lovell's motion. In district court, Lovell argued he had good cause to withdraw his plea because the trial court failed to strictly comply with Utah R. Crim. P. 11(e), which sets out the requirements for a lawful guilty plea. The district court held that the trial court complied with rule 11(e) and that, even if it did not, the error did not amount to good cause to allow Lovell to withdraw his plea because Lovell did not show that but for the error he would not have pled guilty. The Supreme Court reversed, holding (1) the trial court failed to strictly comply with rule 11(e) because the record did not contain statements that clearly and unequivocally informed Lovell of his right to be presumed innocent or his right to a public trial by an impartial jury, and (2) under the "good cause" standard, the trial court's error to strictly comply with rule 11(e) was an error that required reversal. Remanded. View "State v. Lovell" on Justia Law

In this case the juvenile court terminated Father's parental rights to T.E., his biological child, after finding that Father had abandoned T.E. The court of appeals affirmed, concluding that, even if Father did not abandon T.E., there was another permissible ground to terminate Father's parental rights because it was apparent that Father made only "token efforts" to communicate with T.E. The Supreme Court affirmed in part and reversed in part, holding (1) the court of appeals erred in concluding that Father had abandoned T.E. because the court evaluated Father's rebuttal evidence under an incorrect standard; (2) the court of appeals erred in affirming the juvenile court on the alternative ground because it was not apparent on the record that Father made only "token efforts" to communicate with T.E.; and (3) the court of appeals was correct in upholding the juvenile court's use of Father's outbursts at the termination hearing as evidence because they were probative of whether termination of parental rights was in T.E.'s best interest. Remanded. View "R.E. v. B.B." 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

When it was sued by its former president and CEO, the Equine Assisted Growth and Learning Association (EAGALA) requested coverage for the costs of its defense from its insurance carrier, Carolina Casualty. Carolina Casualty denied coverage, contending that the complaint was brought "by, on behalf of, or in the right of" EAGALA, a type of claim excluded from coverage by the insurance policy. EAGALA sued Carolina Casualty to establish coverage for the costs of defending the suit. The district court granted Carolina Casualty's motion for judgment on the pleadings and dismissed EAGALA's complaint after determining that it was unnecessary and improper for the court to consider extrinsic evidence to discern whether Carolina Casualty had a duty to defend EAGALA. The court of appeals reversed, concluding that under the language of the insurance policy, extrinsic evidence was admissible to determined whether the complaint was actually filed by, on behalf of, or in the right of EAGALA. On review, the Supreme Court affirmed the court of appeals' decision, holding that the district court erred when it refused to consider extrinsic evidence as required by the terms of the insurance policy. View "Equine Assisted Growth & Learning Ass'n v. Carolina Casualty Ins. Co." 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

Curtis Allgier was charged with aggravated murder, disarming a peace officer, aggravated escape, aggravated robbery, and aggravated attempted murder. While Allgier's case was pending, the district court received a letter written by an inmate in county jail alleging that Allgier had admitted his guilt to the inmate. After the court provisionally sealed the letter, the local media filed a motion to unseal the letter. The district court granted the motion, concluding that the letter was a court record under the Utah Code of Judicial Administration (UCJA) and that the public had a right of access to the letter. The Supreme Court granted Allgier's petition for interlocutory appeal of the district court's ruling. The Court affirmed the district court's decision to unseal the letter, holding (1) the district court correctly determined that the letter at issue was entitled to a presumptive right of public access under the UCJA, and (2) the district court correctly concluded that Allgier failed to overcome that presumptive right of public access. View "State v. Allgier" on Justia Law

Mother and Stepfather filed a petition in the district court to terminate the parental rights of Father. At the same time, Stepfather filed an adoption petition in which he sought to adopt Father's children. The district court terminated Father's parental rights. The court of appeals reversed the district court's order and remanded, concluding that it was unclear whether the district court had jurisdiction to to terminate Father's parental rights. The Supreme Court granted certiorari and reversed the court of appeals' decision, holding (1) the court of appeals did not err when concluding that an adoption petition must be filed before a district court has jurisdiction to consider a petition to terminate parental rights; and (2) the court of appeals erred in concluding that, in the context of a stepparent adoption, a stepparent must satisfy the requirements contained in section 78B-6-135(7)(b) of the Utah Adoption Act before a district court is vested with authority to consider a petition to terminate parental rights. Remanded. View "In re R.B.F.S." on Justia Law