Justia Utah Supreme Court Opinion Summaries

In this quiet title action, the Supreme Court affirmed the district court's denial of Plaintiffs' motion for summary judgment, holding that the Wrongful Lien Act, the statute of frauds, and caselaw have not declared that restrictive covenants recorded without the signature of the affected landowner are absolutely void. In 1973, Charles Lewton signed and recorded documents purporting to create a homeowners association (HOA) covering 2,000 acres of land. Landowners purchased properties within the HOA's boundaries. In 2015, Landowners discovered that Lewton had owned just eight acres of the 2,000 acres purported to be included in the HOA, and no other landowners signed the recorded documents. Landowners subsequently brought this action to quiet title to their property, arguing that the HOA and its restrictive covenants were void ab initio based on public policy. The district court denied Landowners' motion for summary judgment, applying the two-factor test set forth in Ockey v. Lehmer, 189 P.3d 51 (Utah 2008). The Supreme Court affirmed, holding that restrictive covenants that are recorded without the signature of the affected landowner are voidable and therefore ratifiable. View "WDIS, LLC v. Hi-Country Estates Homeowners Ass'n" on Justia Law

The Supreme Court reversed the decision of the court of appeals construing F.L.'s motion to intervene in David Chadwick's appeal from his sexual abuse of a child conviction as a motion to file an amicus brief under Utah R. App. P. 25 and allowing her thirty days to file the amicus brief, holding that F.L. should be allowed to proceed as a limited purpose party to assert her privacy interests.F.L. was the alleged victim of the sex crimes charged against Chadwick. During proceedings below, the court granted Chadwick's request to conduct an in camera review of F.L.'s therapy and counseling records. The court then sealed the records, and Chadwick was convicted. On appeal, the court of appeals first unsealed F.L.'s records and allowed Chadwick to make use of those records and then granted F.L.'s request to reseal her records and strike all references to the records in Chadwick's supply brief. When Chadwick argued on appeal that the sealing order violated his rights F.L. moved to intervene as a limited-purpose party to assert her privacy interests. The court of appeals construed the motion as a request for leave to file an amicus brief and granted it. The Supreme Court granted extraordinary relief, holding that the court of appeals made a mistake of law in not allowing F.L. to intervene as a limited-purpose party. View "F.L. v. Court of Appeals" on Justia Law

The Supreme Court reversed the determination of the court of appeals that Claimant's long drive in a commercial truck was not an unusual or extraordinary activity in comparison to the ordinary activities people perform in their nonworking, everyday lives and vacated the conclusion that there was substantial evidence to support the ALJ's finding that Claimant's "super obesity" was a preexisting condition, holding that Claimant was entitled to benefits.At the end of a three-day drive from Utah to California, Claimant was diagnosed with a blood clot in his left leg, which caused blood clots in his lungs. Claimant could not return to work and sought workers' compensation. Employer disputed the claim, arguing that his injuries were caused by his "super obesity" and that super obesity should be considered a preexisting condition under the circumstances. The ALJ granted benefits, concluding that Claimant had satisfied the Allen v. Industrial Comm'n, 729. P.2d 15 (Utah 1986), test for legal causation. The Labor Commission Appeals Board reversed, concluding that Claimant's work activities were not unusual or extraordinary under Allen. The Supreme Court reversed, holding (1) Claimant's drive to California was an unusual activity; and (2) therefore, Claimant showed legal causation. View "JBS Carriers v. Hickey" on Justia Law

The Supreme Court reversed in part and affirmed in part the judgment of the district court granting Volkswagen SouthTowne's motion for judgment as a matter of law and a new trial after Plaintiff was awarded $2,700,000 on her negligence and strict liability claims, holding that SouthTowne was not entitled to judgment as a matter of law or a new trial.SouthTowne sold Plaintiff a vehicle that was subject to a safety recall because of defective fuel injection lines. After buying the car, Plaintiff was diagnosed with carbon monoxide poisoning. A mechanic discovered that the safety recall had not been performed on Plaintiff's vehicle. A jury returned a verdict in favor of Plaintiff, but the district court entered post-trial orders concluding that Plaintiff had failed sufficiently to establish the applicable standard of care. The Supreme Court reversed in part, holding (1) the cumulative evidence adduced at trial was legally sufficient to satisfy the element of causation; and (2) the trial court erred in basing its ruling conditionally granting a new trial to SouthTowne because the ruling was based on issues that Plaintiff was not given notice and an opportunity to be heard on. View "Smith v. Volkswagen Southtowne, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating Defendant's convictions on the grounds that his counsel had been ineffective, holding that errors on the part of trial counsel did not prejudice Defendant.Defendant was convicted of murder and several related charges. The court of appeals vacated the convictions, determining that trial counsel was ineffective in failing to object to the use of evidence about Defendant's silence while being arrested and in not objecting to the manslaughter jury instruction, prejudicing Defendant. The Supreme Court reversed, holding (1) defense counsel was ineffective for not objecting to the manslaughter jury instruction, which incorrectly shifted the burden of proof for imperfect self-defense, but the error was not prejudicial; and (2) assuming that defense counsel was ineffective for failing to object to commentary by the prosecution in Defendant's silence after arrest, the error was not prejudicial. View "State v. Bonds" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing the challenges brought by Salt Lake City to four provisions of the Utah Inland Port Authority Act, holding that the challenged zoning provisions did not violate the Utah Constitution.The Act requires that Salt Lake City, West Valley City, and Magna adopt specific zoning regulations and permissions favorable to developing an inland port in the area. Salt Lake brought this action alleging that four provisions of the Act violated the Utah Constitution's Uniform Operation of Laws and Ripper clauses. The district court rejected the City's claims. The Supreme Court affirmed, holding (1) the zoning provisions were rationally related to a legitimate legislative purpose and therefore did not violate the Uniform Operation of Laws Clause; and (2) the zoning provisions did not delegate municipal functions in violation of the Ripper Clause. View "Salt Lake City Corp. v. Inland Port Authority" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that the conduct of two court personnel while sharing a nonpublic courthouse elevator with a jury during trial triggered a rebuttable presumption of prejudice against Defendant, holding that the court of appeals did not err.The court personnel in this case - a uniformed highway patrolman and a court IT technician - told the jurors, in so many words, to find Defendant guilty and to "hang him." The trial court bailiff also stood in the elevator but did not intervene in the exchange. The court of appeals reversed Defendant's conviction and remanded the case for a new trial. The Supreme Court affirmed, holding that the impermissible contact violated Defendant's right to an impartial jury and triggered a rebuttable presumption that Defendant was prejudiced as a result. The Court remanded the case to the district court for a determination of whether the State met its burden to rebut this presumption. View "State v. Soto" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals upholding the decision of the Utah Procurement Policy Board to dismiss ICS Corrections, Inc.'s appeal of the decision of the Utah Division of Purchasing and General Services to award a multi-year telecommunications contract to another bidder, holding that the Board neither clearly erred nor acted arbitrarily or capriciously in dismissing ICS's appeal on the basis that it failed to attach a copy of the protest decision to its notice of appeal within the appeal deadline.In declining to disturb the Board's decision, the court of appeals held that the statutory requirements outlined in the pertinent provision of the Utah Procurement Code compelled strict compliance with their terms. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the Legislature has unequivocally required the Board to dismiss an appeal where the appellant has failed to attach a copy of the protest decision to its notice of appeal within the appeal deadline; and (2) therefore, ICS's appeal must be dismissed. View "ICS Corrections, Inc. v. Procurement Policy Board" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing this case claiming that the Traverse Ridge Special Service District needed either to stop charging members The Cove at Little Valley Homeowners Association for services it had never provided or to start plowing snow from private roads in front of homes in the Cove, holding that the district court erred in part.The Service District filed a motion to dismiss for failure to state a claim because the Draper City Code did not require it to service private roads and because the Homeowners Association needed to bring its challenge in a manner dictated by the Utah Tax Code. The Supreme Court affirmed the district court's dismissal of the Cove's first cause of action but reversed its dismissal of the second reversed in part, holding that the district court erred when it concluded that the assessment its members paid to the Service District was a tax as a matter of law. View "Cove at Little Valley Homeowners Ass'n v. Traverse Ridge Special Service District" on Justia Law

Saltz, a plastic surgeon, was sued by a former patient for releasing her photographs to a news outlet. Saltz submitted his legal defense to his malpractice insurance provider, UMIA, which initially defended Saltz but sought a declaratory judgment, claiming that Saltz lacked insurance coverage for the former patient’s claims. The district court found that Saltz was not covered under the plain language of the policy and dismissed his claim for waiver and his request for punitive damages but denied UMIA’s motion for judgment as a matter of law and allowed Saltz’s promissory estoppel and breach of the duty of good faith claims. Over UMIA’s objections, the court also allowed evidence from a settlement negotiation to be presented to the jury, which found in favor of Saltz on both claims.The Utah Supreme Court affirmed in part, reversed in part, and remanded for further proceedings on Saltz’s requests for punitive damages and for attorney fees incurred on appeal. The district court properly allowed Saltz’s claims for promissory estoppel and breach of the duty of good faith to go to the jury; the court was correct to deny UMIA’s motion for a new trial on the claim for breach of the duty of good faith. The court upheld the admission of evidence from the settlement talks. The district court erred in dismissing Saltz’s claims for waiver and for punitive damages. View "UMIA Insurance, Inc. v. Saltz" on Justia Law