Justia Utah Supreme Court Opinion Summaries

After exiting his brother’s truck at a busy intersection, Pierce fatally shot Toala. After receiving his Miranda warnings, Pierce claimed that he acted in self-defense. His statement was later suppressed. There were multiple witnesses, who disagreed about whether Toala was aggressive or threatening toward Pierce. The Utah Supreme Court affirmed Pierce’s conviction for manslaughter by imperfect self-defense as supported by sufficient evidence. The court rejected an argument that the trial court committed plain error by failing to “sua sponte” cut off the prosecution’s questions and comments about the differences between Pierce’s trial testimony and what he told the police. The law concerning any error was not clear at the time of trial. View "State v. Pierce" on Justia Law

The Supreme Court reversed the decision of the Labor Commission Appeals Board dismissing Appellant's interlocutory objection to the appointment of the medical panel assigned to resolve this dispute, holding that the actual bias standard applied by the Board to resolve Appellant's conflict of interest objection did not comport with the statutory requirements.Appellant sought workers' compensation benefits after he injured his back in a work-related accident. The administrative law judge assigned to the case appointed a medical panel to resolve the dispute and appointed Dr. Jeremy Biggs, an occupational medicine physician, to serve as the panel chair. Appellant moved for interlocutory review, arguing that Dr. Biggs should be disqualified because he had a conflict of interest. The Board rejected Appellant's objections and concluded that the accident had not caused permanent injury. The Supreme Court reversed, holding (1) where a medical panelist's impartiality could be reasonably questioned the requirement of an impartial medical evaluation has not been met; and (2) remand was required on this basis. View "Gamez v. Utah Labor Commission" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the conclusion of the district court dismissing Plaintiff's complaint against Washington County School District claiming that the School District had failed to offer it the right of first refusal to repurchase its former property, holding that the court of appeals erred in its interpretation of Utah Code 78-34-20(1)(b), replaced by Utah Code 78B-6-521(1)(a)(ii).Several years after Plaintiff sold a parcel of land to the School District the School District resold the property. Because Utah law requires a government entity to offer property acquired through condemnation or a threat of condemnation to the original owner before disposing of it Plaintiff bought suit, arguing that the School district acquired its property under a threat of condemnation. The district court dismissed the suit for failure to state a claim. The court of appeals affirmed, concluding that a government entity does not specifically authorize the use of eminent domain until it approves an eminent domain lawsuit in an open meeting. The Supreme Court reversed, holding that the statute did not support the appellate court's interpretation of what it means to be specifically authorized. View "Cardiff Wales, LLC v. Washington County School District" on Justia Law

The Supreme Court held in this interlocutory appeal that the district court may not judge the sufficiency of the defendant's showing necessary to overcome a motion to quash based solely on an in camera proffer without first affording the State an opportunity to respond.Defendant was charged with seven felony charges for an alleged pattern of sexual abuse in connection with A.W. over the course of several years while Defendant was A.W.'s pastor. Defendant denied the charges and served A.W. with a subpoena to appear and testify at his preliminary hearing. A.W. moved to quash the subpoena. Defendant moved to make the showing necessary to overcome the motion to quash in camera and only in the district court. The district court granted the motion. The Supreme Court reversed, holding that Defendant must make his proffer under State v. Lopez, 474 P.3d 949 (Utah 2020), in open court, giving the State an opportunity to respond. View "State v. Archibeque" on Justia Law

The Supreme Court affirmed the decision of the district court denying Landowners' motion for summary judgment in their action to quiet title to their property against a homeowners association (HOA), holding that the district court did not err.Landowners purchased properties within the boundaries of the HOA but later discovered that the person who signed and recorded the documents purporting to create the HOA owned a mere 0.4 percent of the territory he sought to include within the boundaries of the HOA, and no other landowners had signed the recorded documents. Landowners, who met resistance in trying to develop their property, brought this action alleging that the HOA and its subsequently amended restrictive covenants were void ab initio. The district court denied Landowners' motion for summary judgment. On appeal, Landowners argued that the covenants must be declared absolutely void under the 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, not absolutely void. View "WDIS, LLC v. Hi-Country Estates Homeowners Ass'n" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant's motion brought under Utah R. Civ. P. 70(b) or, alternatively, as a motion for a misplea, arguing that the prosecution breached the parties' plea agreement, holding that Appellant's constitutional challenge to his guilty plea was properly considered only under the Post-Conviction Remedies Act (PCRA).Appellant was charged with aggravated murder and other counts related to making and transporting a bomb. Pursuant to a plea agreement, Appellant pled guilty to depraved indifference murder. Twenty-three years later, Appellant brought this motion, arguing that there was no other available avenue for relief. The district court dismissed the motion. The Supreme Court affirmed, holding that Appellant's claim should have been brought under the PCRA. View "State v. Thurman" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court dismissing Honnen Equipment Company's (Honnen) breach of contract claim brought brought against Daz Management, LLC (LLC), holding that all elements of claim preclusion were met, and therefore, the breach of contract claim was barred.Honnen sued Tony Daz (Daz) claiming that Daz negligently operated and damaged a grader that had been rented by the LLC from Honnen and thus breached the rental agreement. The district court ruled for Daz on both Honnen's breach of contract and negligence claim. Thereafter, Honnen brought a second action against the LLC asserting the same claims. After Honnen voluntarily dismissed its negligence claim the district court dismissed the breach of contract claim under the claim preclusion branch of res judicata. The court of appeals reversed. The Supreme Court reversed, holding that Honnen's breach of contract claim was barred. View "Honnen Equipment Co. v. DAZ Management, LLC" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction and the denial of his motion to suppress, holding that the State did not meet its burden in rebutting a presumptively unreasonable seizure.The police found Defendant sleeping in his car in a McDonald's parking lot. The officers asked Defendant to exist his vehicle and ordered him to perform a field sobriety test. Defendant was subsequently charged with driving under the influence of alcohol. Defendant moved to suppress evidence and statements as a result of his seizure, arguing that his seizure and subsequent searches were unlawful. The district court denied the motion, concluding that Defendant's seizure was justified by the community caretaking doctrine. The Supreme Court reversed, holding that the State did not meet is burden to rebut the presumption of unreasonableness. View "State v. Smith" on Justia Law

The Supreme Court affirmed the ruling of the district court convicting Defendant of aggravated battery and denying Defendant's motion for a directed verdict, holding that the evidence was sufficient to support the conviction.A jury convicted Defendant of aggravated robbery. Defendant appealed, arguing that a 911 call was inadmissible hearsay and that its admission at trial was prejudicial error. The Supreme Court affirmed, holding (1) the district court properly admitted the 911 call under the present sense impression exception to the rule against hearsay; and (2) this Court declines to reexamine caselaw requiring criminal appellants to show prejudice from preserved errors. View "State v. Johnson" on Justia Law

The Supreme Court affirmed in part and reversed and vacated in part the juvenile court's order terminating the parental right of Parents, holding that the juvenile court's opinion was too affected by legal error to merit deference on appeal.After a hearing on the termination of parental rights, the juvenile court entered an order terminating the parental rights of both Mother and Father. The court found that both parents were unfit and had neglected the children and that termination was strictly necessary in the best interest of the children. After the adoptive placement with the uncle failed, the parents filed motions for post-judgment relief. The juvenile court denied the motions. The Supreme Court reversed and vacated in part, holding that remand was required for a new best interest determination under the law as clarified in this opinion. View "In re J.L." on Justia Law