Justia Utah Supreme Court Opinion Summaries

This case arose from a lawsuit in federal district court over the death of fifteen-year-old Tucker Thayer. In that suit, Tucker's parents alleged that Washington County School District officials were negligent when they allowed a gun loaded with blank cartridges to be used in a school musical production, resulting in their son's death. The school district asserted governmental immunity from the claims. The Utah Supreme Court accepted certification to address a novel issue of state law and held that the Licensing Exception of the Governmental Immunity Act did not apply to the conduct of the school district officials and those acting on the district's behalf, as any authorization of the presence of the firearm on campus was not a formal, official authorization by a governmental body or employee endowed with regulatory power to issue such an authorization. In addition, a governmental entity such as the school district may not insulate itself from suit by routinely authorizing and approving the negligent conduct of its employees. View "Thayer v. Thayer" on Justia Law

In July 2006, Appellee Staker & Parson Companies (Staker) worked as a contractor for the Utah Department of Transportation on an interstate construction project. Appellant Kent Turner sustained serious injuries in a car accident near the work site. He filed suit for negligence against Staker in July 2010, nearly four years after the accident. The district court granted Staker's motion to dismiss, holding that Turner's suit was time-barred under Utah Code 78B-2-225(3)(b)'s two-year statute of limitations. On appeal, Turner argued that his claim qualified for a four-year statute of limitations under Utah Code 78B-2-225(8). The Supreme Court reversed, holding that Turner's complaint alleged sufficient facts to survive dismissal under section 78B-2-225(8). Remanded. View "Turner v. Staker" on Justia Law

Wolfgango Ruiz pled guilty to one count of attempted sexual abuse of a child, a third degree felony. Prior to his sentencing, Ruiz made a request to withdraw his plea on the ground that his original defense counsel had not informed him of the immigration consequences of a felony conviction. District Court Judge Fuchs initially granted Ruiz's motion, but upon a motion to reconsider, Judge Skanchy reversed the order that permitted Ruiz to withdraw his plea. The court of appeals reversed Judge Skanchy's ruling and reinstated Judge Fuch's order based on Judge Skanchy's failure to state the basis for his ruling on the record and the principal that motions to withdraw guilty pleas should be liberally granted. The Supreme Court reversed, holding (1) the court of appeals err in vacating Judge Skanchy's ruling because the basis for the ruling was apparent on the record; and (2) recent amendments to the Plea Withdrawal Statute superseded prior case law stating that presentence motions to withdraw guilty pleas should be liberally granted. Remanded. View "State v. Ruiz" on Justia Law

This appeal encompassed two consolidated cases. In the first case, Charles Moa entered a no contest plea to a third degree felony but later filed motions to withdraw that plea. Moa first stipulated that his plea was taken in compliance with Utah R. Crim. P. 11 but, on appeal, argued that his plea was not taken in compliance with Rule 11. The court of appeals held that Moa failed to demonstrate plain error in the district court's denial of his motions. In the second case, Moa pled guilty to two felonies and a misdemeanor. The sentencing judge imposed consecutive sentences. The court of appeals affirmed, rejecting Moa's argument that the sentencing judge relied on irrelevant information in imposing the sentences. The Supreme Court affirmed, holding (1) in the first case, by stipulating that his plea was taken in compliance with Rule 11, Moa invited any error that may have been committed by the district court; and (2) in the second case, the court of appeals was correct in concluding that there was no evidence that the district court relied on any improper information in imposing consecutive sentences. View "State v. Moa" on Justia Law

James Alexander pled guilty to burglary with intent to commit sexual battery. Prior to sentencing, Alexander filed a timely motion to withdraw his guilty plea, arguing (1) the district court failed to apprise him of the elements of sexual battery as required by Utah R. Crim. P. 11, and (2) his plea was not knowingly and voluntarily made. The court denied Alexander's motion and sentenced him accordingly. The court of appeals reversed, concluding (1) the district court did not comply with Rule 11 at the plea hearing because it did not inform Alexander of the elements of sexual battery, and (2) the violation of Rule 11 rendered the plea unknowing and involuntary. The Supreme Court affirmed, holding (1) although the court of appeals erred in limiting its review to whether the district court had complied with Rule 11 during the plea hearing, the record demonstrated that Alexander's plea was not knowingly and voluntarily made; (2) the court of appeals did not err in declining to require a showing of prejudice; and (3) because this case involved a different issue than the one addressed in the Court's holding in Hurst v. Cook, the two cases did not conflict. View "State v. Alexander" on Justia Law

Troy Kell was convicted of murder and sentenced to death. Kell subsequently filed a petition for postconviction relief, alleging ineffective assistance of trial counsel, which the district court dismissed. The Supreme Court affirmed. Kell thereafter filed a Utah R. Civ. P. 60(b) motion, asking the district court to relieve him from its earlier dismissal of his petition for postconviction relief. The district court denied the motion, holding that because Kell's postconviction petition had been dismissed, appealed, and affirmed on appeal, the underlying denial of his petition for postconviction relief was no longer "pending" and thus the court could not consider the merits of the 60(b) motion. The Supreme Court affirmed on alternate grounds, holding (1) Rule 60(b) does not have a "pending" requirement and is not necessarily inappropriate in all cases in which the Court has already ruled, but it may not be used as a way to circumvent the Post-Conviction Remedies Act (PCRA); and (2) in this case, Kell's claims were barred by the PCRA and therefore could not be brought under Rule 60(b). View "Kell v. State" on Justia Law

A group of residential tenants (collectively, Tenants) alleged claims of negligence against Canyon Cover Properties, LLC and Apartment Management Consultants, LLC (collectively, AMC). AMC argued that it was relieved from liability because Tenants signed a residential lease agreement (Agreement) that included a limited liability provision (Exculpatory Clause) waiving the right to bring an action for negligence against AMC. The district court concluded that the Agreement and Exculpatory Clause did not violate public policy and were therefore valid and enforceable, and accordingly, granted summary judgment for AMC. The Supreme Court reversed, holding that because AMC failed to respond meaningfully to Tenants' claim that the Exculpatory Clause was unenforceable because it violated public policy, AMC's brief was rejected and Tenants' claim was accepted that the Exculpatory Clause in the Agreement was unenforceable. Remanded. View "Broderick v. Apartment Mgmt. Consultants, LLC" on Justia Law

This protracted litigation arose out of a real-property exaction imposed on B.A.M. Development, LLC, as a condition of a construction permit for a fifteen-acre residential housing development. Twice the Supreme Court remanded the case for a new trial. After conducting a third trial, the district court concluded that the County's exaction did not violate the Dolan v. City of Tigard rough proportionality standard. The Supreme Court affirmed the district court in all respects, holding (1) the district court did not err by including in its rough-proportionality analysis costs borne by state government entities; (2) the district court did nor err by limiting the scope of its review to B.A.M.'s thirteen-foot road dedication; and (3) B.A.M.'s remaining arguments were meritless or inadequately briefed. View "B.A.M. v. Salt Lake County" on Justia Law

Plaintiff's son, Hayden, was involved in a near-drowning accident in which he suffered severe permanent injuries. Plaintiff subsequently sought coverage for the cost of his treatment from Wasatch Crest Mutual Insurance, under which Hayden was insured. Wasatch Crest was later declared insolvent, and Plaintiff filed a claim against the Wasatch Crest estate. The liquidator of the estate denied Plaintiff's claim, concluding that Wasatch Crest had properly terminated coverage under the language of the plan. The Supreme Court reversed, interpreting the plan in favor of coverage. Plaintiff resubmitted her claim for medical expenses to the liquidator for payment under the Utah Insurers Rehabilitation and Liquidation Act. One year later, Plaintiff filed a motion for summary judgment with the district court. The liquidator subsequently issued a second amended notice of determination denying Plaintiff's claim on the merits. The district court then denied Plaintiff's motion for summary judgment, as Plaintiff had not yet challenged the second amended notice of determination and could do so under the Liquidation Act. Plaintiff appealed the district court's order. The Supreme Court dismissed the appeal because Plaintiff did not appeal from a final judgment and had not satisfied any of the exceptions to the final judgment rule. View "Mellor v. Wasatch Crest Mut. Ins." on Justia Law

Upon adjudication of parental neglect, the Division of Child and Family Services (DCFS) took custody of L.O., a child and an enrolled member of the Navajo Nation, and placed L.O. with a foster family. After L.O.'s natural parents relinquished parental rights, L.O.'s foster family filed a petition for adoption. The Nation filed an objection to the adoption because DCFS failed to abide by the placement preferences contained in the Indian Child Welfare Act and moved the juvenile court to transfer jurisdiction to the Nation. The juvenile court denied the transfer motion. The Nation appealed, and the court of appeals dismissed the case. After the Supreme Court granted certiorari to consider two procedural questions raised by the Nation, the juvenile court granted the foster family's petition to adopt L.O. Filed with the adoption order was a document titled "Navajo Nation's Consent to Adoption." The Supreme Court declined to address the issues raised on certiorari and dismissed the petition for certiorari, holding that the Nation's consent to L.O.'s adoption placement rendered the procedural questions moot. View "Navajo Nation v. State " on Justia Law