Justia Utah Supreme Court Opinion Summaries

The case involves a dispute over the Utah Legislature's repeal and replacement of a citizen initiative known as "Proposition 4," which aimed to reform the state's redistricting process to prevent partisan gerrymandering. Proposition 4, passed by Utah voters in 2018, established an Independent Redistricting Commission and set forth neutral redistricting standards, including a prohibition on partisan gerrymandering. However, before the next redistricting cycle, the Utah Legislature enacted Senate Bill 200 (S.B. 200), which repealed Proposition 4 and replaced it with a new law that did not include the same anti-gerrymandering provisions and weakened the role of the Independent Commission.In the Third Judicial District Court, Salt Lake County, the plaintiffs argued that the Legislature's actions violated the Utah Constitution by nullifying the reforms enacted by the people through Proposition 4. The district court dismissed this claim, holding that the Legislature has the authority to amend or repeal any statute, including those enacted by citizen initiative, without limitation. The plaintiffs appealed this decision.The Utah Supreme Court reviewed the case and focused on two constitutional provisions: the Initiative Provision in article VI, section 1, which grants the people the power to initiate legislation, and the Alter or Reform Clause in article I, section 2, which states that the people have the right to alter or reform their government. The court concluded that these provisions, when read together, limit the Legislature's power to amend or repeal a citizen initiative that reforms the government. The court held that the people’s right to reform the government through an initiative is constitutionally protected from legislative actions that would impair the reform enacted by the people.The Utah Supreme Court reversed the district court's dismissal of Count V, which challenged the Legislature's repeal and replacement of Proposition 4, and remanded the case for further proceedings. The court emphasized that legislative changes to a government-reform initiative must not impair the reform and must be narrowly tailored to advance a compelling government interest if they do. View "League of Women Voters v. Utah State Legislature" on Justia Law

The case revolves around Brent Gordon's claim that Herriman City's policy violates his right to inspect records under the Utah Government Records Access and Management Act (GRAMA). Gordon did not appeal Herriman’s denial of a records request but instead sued for an injunction that would require Herriman to allow him to inspect any public record free of charge. The district court dismissed Gordon’s case, concluding that he needed to submit a formal records request and exhaust his administrative remedies before bringing suit.The district court agreed with Herriman City and dismissed Gordon’s claim. The court ruled that Gordon was not entitled to judicial review because he either did not make a formal GRAMA request or, if he did, he did not fully exhaust the administrative remedies associated with that request. Gordon appealed the district court’s decision to the Supreme Court of the State of Utah.The Supreme Court of the State of Utah affirmed the district court's decision. The court found that Gordon lacked statutory standing to pursue his claim. The court explained that the injunction provision in Utah Code section 63G-2-802(1), which Gordon relied on, merely provides a remedy and does not create a right of action. The court concluded that without an express or implied statutory right to seek judicial review of Herriman’s alleged policy, Gordon lacked statutory standing to pursue this action. Therefore, the district court lacked jurisdiction to adjudicate his GRAMA claim and correctly dismissed it. View "Gordon v. Nostrom" on Justia Law

A group of Utah voters, led by Ian Daniel Phillips, sought to initiate state legislation that would impose an age limit on Utah candidates for federal office. The Lieutenant Governor of Utah rejected the group's initiative application, concluding that the proposed law was "patently unconstitutional" under U.S. Term Limits, Inc. v. Thornton, a Supreme Court case that forbids states from enacting laws imposing qualifications on candidates for federal congressional office. The group then sued the Lieutenant Governor, seeking a declaration that the initiative is not patently unconstitutional and could become law if enacted.The district court dismissed the group's complaint, ruling that the proposed initiative is "squarely foreclosed by" Thornton, a decision that the court had no authority to overrule. The group appealed, maintaining that Thornton should be overruled because its prohibition on state-created qualifications for federal officeholders violates the Tenth Amendment of the United States Constitution. However, they acknowledged that the Supreme Court of the State of Utah lacks authority to overturn Thornton and asked the court to affirm the district court’s decision, thereby paving the way for them to petition the United States Supreme Court for review.The Supreme Court of the State of Utah affirmed the district court's ruling. The court held that the group had appellate standing, despite their concession that they cannot prevail at this stage of the appeal. The court also agreed with the district court that the proposed law is patently unconstitutional under Thornton. Therefore, the group did not state a claim upon which relief may be granted. View "Phillips v. Henderson" on Justia Law

In 2020, the Town of Hideout, Utah, took advantage of a brief window in state law that allowed municipalities to annex unincorporated areas without a petition or county consent. Hideout annexed an area in Summit County, and after receiving a certificate of annexation from the Lieutenant Governor, Summit County challenged the annexation and the related municipal ordinance in district court. The district court ruled in favor of Summit County, finding that it had standing to challenge the annexation and declaring the annexation ordinance invalid.The Supreme Court of the State of Utah reversed the district court's decisions. The court found that the relevant statutory scheme, the annexation code, did not provide Summit County with a legally protectible interest that would allow it to obtain the relief it sought. The court also found that the statutory provisions outside the annexation code that Summit County relied on did not provide it with a legally protectible interest in the controversy. The court further held that the doctrine of public interest standing, on which the district court alternatively relied, was inapplicable in this case.Because the court concluded that Summit County lacked standing to pursue its claims, it also reversed the district court’s award of summary judgment in Summit County’s favor without addressing the merits of Summit County’s claims. The case was remanded to the district court for dismissal. View "Hideout v. Summit County" on Justia Law

In 2018, a group of citizens in Tooele County, Utah, initiated the process to incorporate an area known as the City of Erda. The incorporation process involved several steps, including obtaining signatures from property owners within the proposed area, conducting a feasibility study, and holding a public vote. After the incorporation was certified by the Lieutenant Governor, three landowners within Erda's boundaries—John Bleazard, Mark Bleazard, and Six Mile Ranch Company—challenged the incorporation. They alleged that the incorporation process violated statutory requirements, including that their signatures were misrepresented in the feasibility study request and that the notice of impending boundary action was untimely.The district court in Tooele County denied motions to dismiss the case brought by the City of Erda and the Lieutenant Governor. They had argued that the landowners lacked statutory standing to challenge the incorporation. The court disagreed, finding that the landowners had a legally protectible interest under the Utah Code, which it interpreted as contemplating the possibility of a challenge to an incorporation.The Supreme Court of the State of Utah reversed the district court's decision. The Supreme Court held that the landowners' claim for declaratory relief was non-justiciable because they lacked a legally protectible interest in the controversy. The court found that the landowners did not have a private right of action to enforce the requirements of the incorporation code. The court concluded that the landowners' claim must be dismissed as a matter of law. View "Bleazard v. City of Erda" on Justia Law

In Utah, a group of local citizens sponsored the incorporation of an area in Tooele County to be known as the City of Erda. After the Lieutenant Governor certified Erda’s incorporation, three landowners within Erda’s boundaries challenged the incorporation, alleging statutory violations during the incorporation process. The defendants, Erda and the Lieutenant Governor, moved to dismiss the complaint, arguing that the landowners lacked statutory standing. The district court disagreed and denied their motions to dismiss.The defendants appealed to the Supreme Court of the State of Utah, arguing that the landowners' claim for declaratory relief should be dismissed as it is non-justiciable. The Supreme Court agreed, holding that the landowners’ claim must be dismissed as a matter of law because it is non-justiciable. The court found that under Utah law, a declaratory judgment action is non-justiciable if the plaintiff lacks a protectible legal interest in the controversy. The court concluded that the landowners did not have a protectible legal interest in their claim because the legislature did not grant affected citizens a private right of action to enforce the incorporation code’s requirements. Therefore, the court reversed the district court’s decision. View "Bleazard v. Henderson" on Justia Law

The case involves the trustees of the Stanley and Sandra Goldberg Trusts, C. Leon Nelson and Marilynn Tetrick, who hired legal counsel to assist them in their duties. The same attorneys later defended them in a lawsuit brought by several beneficiaries of the trusts. The jury found that the trustees had breached their fiduciary duties, and the district court entered a judgment against them, most of which was payable to the trusts. The court then removed the trustees and appointed successor trustees. The former trustees, still represented by the same attorneys, asked the court to reduce the amount of the judgment against them. The successor trustees moved to disqualify the former trustees’ attorneys, arguing that a conflict had surfaced under rule 1.9(a) of the Utah Rules of Professional Conduct. The district court agreed and disqualified the attorneys.On appeal, the Supreme Court of the State of Utah reversed the district court's decision. The Supreme Court held that an attorney-client relationship does not automatically arise merely because an attorney represents a trustee. In this case, the attorneys represented the former trustees only, not the trusts, which were not named in the suit. Thus, because the attorneys never represented the trusts in the litigation, rule 1.9(a) does not prevent the attorneys from continuing to represent the former trustees. View "In re Estate of Goldberg" 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

The case involves Shane Craig Smith, who was arrested in a police sting operation after he attempted to engage in sexual activities with a persona named "Emily," who he believed to be a 13-year-old girl. Smith had met Emily online and had arranged to meet her at a gas station in Lehi, Utah, with the intention of having her perform multiple sex acts in exchange for driving her to California. Smith was charged with various crimes, including attempted child kidnapping, attempted rape of a child, and attempted sodomy of a child. He pled guilty to most of these charges while reserving the right to appeal two issues: whether there was sufficient evidence to bind him over for trial on the attempt charges, and whether he was entrapped as a matter of law.Smith's case was first heard in the district court, where he moved to decline to bind over the counts of attempted rape of a child, attempted sodomy of a child, and attempted kidnapping of a child. He argued that the State’s evidence regarding the attempt crimes did not show that his actions rose beyond solicitation or mere preparation and was therefore insufficient to support probable cause on the “substantial step” element of the attempt statute. The district court denied the motion and bound over all counts for trial. Smith then filed a motion to dismiss all charges on entrapment grounds, which the district court denied. Smith eventually entered a conditional guilty plea to attempted child kidnapping, attempted sodomy of a child, and enticement of a minor, allowing him to appeal the district court’s bindover ruling and entrapment determination.Smith appealed to the Utah Court of Appeals, where he raised two issues: whether there was insufficient evidence to bind over the attempt charges for trial, and whether the district court erred by denying his motion to dismiss all the charges on the basis that he had been entrapped. The court of appeals affirmed the district court’s rulings. Smith then petitioned for certiorari to the Supreme Court of the State of Utah.The Supreme Court of the State of Utah affirmed the decisions of the lower courts. The court found that Smith's actions constituted substantial steps toward the commission of the crimes he was charged with, and that he was not entrapped as a matter of law. The court held that Smith's actions strongly corroborated his intent to commit the crimes, and that the police conduct in the case did not create a substantial risk that an average person would attempt to commit the crimes that Smith attempted. View "State v. Smith" on Justia Law

Nicholas and Julie Kuhar filed a product liability claim against Thompson Manufacturing, a Utah company, seeking compensation for injuries Nicholas sustained when his safety harness failed while he was cleaning rain gutters in New Jersey. This was not the first lawsuit the Kuhars had brought regarding this incident. They had previously sued Thompson and other defendants in New Jersey federal court, alleging that the harness was defective. That suit was unsuccessful, with Thompson being dismissed from the case due to a lack of personal jurisdiction. The Kuhars then refiled their claims against Thompson in Utah.In the New Jersey case, the Kuhars' expert witness was excluded, and the remaining defendants were granted summary judgment. Thompson then moved in the Utah case to preclude the Kuhars from litigating the issue of whether the harness was defective. The district court agreed with Thompson and dismissed the Kuhars' claims. However, the Utah Court of Appeals reversed this decision, concluding that the issue litigated and decided in New Jersey was not identical to the issue Thompson sought to preclude in Utah.The Supreme Court of the State of Utah, however, disagreed with the Court of Appeals. It concluded that the elements of issue preclusion were satisfied. The court clarified that to determine the issue-preclusive effect of the New Jersey federal court’s judgment in this case, the substantive law of New Jersey applies. Under that law, the court concluded that the issue Thompson sought to preclude the Kuhars from litigating—whether the harness was defective—was actually litigated and decided on the merits in the New Jersey court’s summary judgment order. Therefore, the Supreme Court of the State of Utah reversed the decision of the Court of Appeals. View "Kuhar v. Thompson Manufacturing" on Justia Law