Justia Utah Supreme Court Opinion Summaries

The State filed a petition that charge D.B. as a principal with theft and criminal trespass for entering a construction site and removing a pair of bolt cutters. The juvenile court adjudicated D.B. a delinquent as an accomplice on both counts. The court of appeals affirmed. D.B. filed a petition for writ of certiorari, claiming that he did not receive adequate Sixth Amendment notice that he may be adjudicated delinquent as an accomplice for the charges. The Supreme Court reversed the delinquency adjudication on the criminal trespass charge but affirmed it on the theft charge, holding (1) D.B. received constitutionally adequate notice through trial testimony that he faced accomplice liability for theft; but (2) the juvenile court adjudicated D.B. delinquent as an accomplice for criminal trespass without notice. Remanded. View "D.B. v. State" on Justia Law

Defendant was convicted of sexual abuse of a child. At trial, the court admitted evidence of two prior uncharged sexual assaults by Defendant. On appeal, Defendant challenged the admissibility of that evidence under Utah R. Evid. 404(b), asserting either that it was not offered for a non-character purpose or that its probative value was substantially outweighed by a risk of unfair prejudice. The court of appeals deemed the evidence admissible for two non-character purposes and affirmed. The Supreme Court (1) reversed the conviction, holding (i) the court of appeals erred in affirming the admissibility of evidence of Defendant's uncharged misconduct offered to prove his specific criminal intent, which was not a legitimately disputed issue at trial; and (ii) the State's evidence was not admissible to prove Defendant acted in conformity with a plan to entice and abuse young men, as the evidence did not demonstrate that Defendant entered a preconceived, overarching design to commit the acts in question; and (2) remanded for a new trial, leaving the door open for the State to offer its evidence on grounds different from those adopted by the trial court or court of appeals. View "State v. Verde" on Justia Law

Plaintiff underwent several medical procedures performed by Defendants, two medical doctors. Two years and three months after the treatment ended, Plaintiff filed a medical malpractice claim against Defendants. Upon a motion by Dr. Grigsby, one of the doctors, the district court dismissed Plaintiff's claim, finding that the claim was barred by the two-year statute of limitations. The court of appeals reversed. The Supreme Court affirmed but on different grounds, holding (1) the court of appeals correctly found that, as a matter of law, Dr. Grigsby failed to show Plaintiff filed her claim more than two years after she discovered or should have discovered her legal injury; but (2) when a plaintiff alleges a course of negligent treatment, a defendant may show that the claim is barred by the two-year statute of limitations without identifying the specific procedure within the course of treatment that caused the patient's injury. Rather, to prevail, a defendant need only show that the plaintiff filed her claim more than two years after she discovered that the course of treatment was negligent. Remanded. View "Arnold v. Grigsby" on Justia Law

Defendant was charged with possession of methamphetamine and drug paraphernalia after a search of his motel room. The district court declined to bind Defendant over for trial at a preliminary hearing, concluding that every reasonable inference from the evidence was that Defendant did not know of the presence of the drug residue and paraphernalia, and therefore, without evidence of an intent to exercise control, there could be no inference of possession of drug residue or paraphernalia. A divided court of appeals affirmed. The Supreme Court reversed, holding (1) the magistrate's and court of appeals majority's concerns with the evidence were insufficient to foreclose a finding of probable cause; (2) the magistrate and court of appeals overstepped their bounds in favoring Defendant's inference that he "didn't know the drugs were there" as stronger than the prosecution's alternative; and (3) the lack of evidence concerning the exclusivity of Defendant's control and access to the motel room did not defeat the prosecution's showing of probable cause. Remanded with instructions to bind Defendant over for trial. View "State v. Ramirez" on Justia Law

In 2005, Allen Grazer obtained a judgment against Gordon Jones and Richard Barney for breach of contract. To satisfy the judgment, property held by Jones and Barney was sold at a sheriff's sale and purchased by Grazer's attorney on his client's behalf. Jones and Barney assigned their redemption interests to the Olsen Trust, which attempted to redeem the property under Utah R. Civ. P. 69C(c). Grazer challenged that attempt as invalid because it was not in full compliance with Rule 69C(c). The district court granted partial summary judgment in favor of the Olsen Trust, concluding the Trust had substantially complied with the rule. The court of appeals affirmed. The Supreme Court affirmed on somewhat different grounds, holding (1) Rule 69C(c) cannot reasonably be read to require superfluous service of documents on the party who was ultimately their source; and (2) the Olsen Trust's redemption was valid and enforceable despite alleged deficiencies under Rule 69C(c) because the Trust fulfilled all non-superfluous requirements of the rule. View "Grazer v. Jones" on Justia Law

After Michael G. Kampros's death, Mark Green and Sophie Gibson became trustees of the Michael G. Kampros Family Trust. Willow Rapela, Kampros's daughter and the successor trustee, requested removal of Green and Gibson pursuant to section 75-7-706(2)(d) of the Utah Trust Code. The district court granted her request with respect to Gibson but declined to remove Green. The district court held that Green had more experience and better qualifications than Rapela to manage the Trust's assets. As a result the district court concluded that Green's removal would not serve the best interests of the Trust's beneficiaries. The Supreme Court affirmed, holding (1) the district court properly concluded that removal of Green did not serve the beneficiaries' best interests; (2) the district court correctly held that Green's personal interests the LLCs in which the Trust also owned interests did not constitute an impermissible conflict of interest because Kampros knew about Green's interests at the time he appointed Green trustee; and (3) the district court permissibly compared Green's and Rapela's experience and qualifications when evaluating whether removal would serve the beneficiaries' best interests. View "Rapela v. Green" on Justia Law

This appeal was rooted in a dispute over an arbitration award. Each party had selected an arbitrator, and a third neutral arbitrator was selected by the two party-appointed arbitrators. Appellee argued that the award should be vacated because one of the party-appointed arbitrators did not disclose that he was first cousins with one of the shareholders in the opposing counsel's law firm. The district court granted Appellee's motion to vacate arbitration award. The Supreme Court reversed, holding (1) under section 129 of the Utah Uniform Arbitration Act (UUAA), there is no appeal of right from a district court order denying confirmation of an arbitration award, vacating the award, and directing a rehearing; (2) party-appointed arbitrators are held to the disclosure standards of the UUAA and not the standards that apply to neutral arbitrators; and (3) the UUAA does not support vacatur in this case, as (i) under subsection 113(4) of the UUAA, the failure to disclose a relationship can support vacatur only if it also meets one of the provisions outlined in subsection 124(1)(b) of the UUAA; and (ii) none of those provisions was shown in this case. View "WestGate Resorts, Ltd. v. Adel" on Justia Law

Shawn Adel, a former employee of Westgate Resorts, a timeshare company, formed Consumer Protection Group (CPG) to right perceived wrongs stemming from Westgate's offer of certificates to consumers that were virtually irredemable. CPG solicited people who had received certificates to assign their claims to CPG. Westgate sued Adel, claiming intentional interference with existing and potential economic relations, conversion, breach of contract, and violation of the Utah Uniform Trade Secrets Act. Adel and CPG counterclaimed on behalf of 500 claimants, alleging breach of contract, fraudulent inducement, and violation of the Utah Consumer Protection Act. The jury awarded actual economic damages of between $5 and $550 for each claimant and awarded each claimant punitive damages of $66,666. The Supreme Court vacated the jury's punitive damages award, holding that the award violated Westgate's procedural due process rights under Philip Morris USA v. Williams because the statements made by CPG's counsel during closing argument created a risk that the jury would improperly consider harm allegedly caused by Westgate to nonparties when it fixed its punitive damages award. Remanded for a new evaluation of the punitive damages award only. View "WestGate Resorts, Ltd. v. Adel" on Justia Law

After an automobile accident caused severe injury to Plaintiffs, Plaintiffs sued the Utah Department of Transportation (UDOT), alleging that it negligently failed to install median barriers at the scene of the accident. In a special verdict, the jury found UDOT was not negligent, and the court entered a judgment of no award. Plaintiff appealed, and UDOT cross-appealed. The Supreme Court held (1) the district court abused its discretion in refusing to instruct that jury that it should draw no adverse inference from the absence of accident history evidence, and thus the case was remanded for a new trial on that ground; (2) the district court did not err in ruling that the accident history evidence was inadmissible; (3) the district court property handled voir dire and correctly rejected Plaintiffs' proposed jury instructions regarding the statutory damages cap and reserve fund; (4) the jury was properly instructed regarding UDOT's duty of care; and (5) the district court erred in refusing to entertain Plaintiffs' motion to exclude witnesses on the ground that they did not so move at the opening of trial. View "Miller v. Utah Dep't of Transp." on Justia Law

Chad Jones sued his insurance company, Farmers Insurance Exchange, for breach of contract, bad faith breach of contract, and intentional infliction of emotional distress after Farmers denied his claim. Farmers defended by arguing that it did not breach its contract because Jones's claim was "fairly debatable." Farmers claimed this defense must be resolved through summary judgment. The district court granted Farmers' motion for summary judgment. The Supreme Court reversed, holding that the fairly-debatable defense should not be resolved through summary judgment if reasonable minds could differ as to whether the defendant's conduct measures up to the standard required for insurance claim investigations. Remanded. View "Jones v. Farmers Ins. Exch." on Justia Law