Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction on a misdemeanor charge of threatening to use a dangerous weapon in a quarrel with his father, holding that Defendant identified no basis for reversal.The district court concluded that Defendant's "use or threat of the weapon under the circumstances was not necessary or reasonable" and found him guilty as charged. The court of appeals affirmed. Defendant appealed, arguing that the court of appeals erred in affirming the conviction under an "objective standard of reasonableness." The Supreme Court affirmed, holding (1) Defendant did not establish that the court of appeals adopted a standard of reasonableness that differed from the one articulated in this opinion; and (2) Defendant failed to show that there was error in the application of the statutory standard in the district court. View "State v. Sorbonne" on Justia Law

The Supreme Court vacated the decision of the district court denying the motion for summary judgment filed by Barnes Bullets asking the district court to rule that the Workers' Compensation Act (WCA) barred Layne Kay's claim, holding that the Occupational Disease Act (ODA) may bar Kay's lawsuit.Kay contracted lead poisoning while working at Barnes and sued Barnes under the exception to the WCA permitting employees like Kay to sue over injuries caused by an employer's intentional act. Barnes moved for summary judgment, arguing that the WCA barred Kay's claim where Kay did not present sufficient evidence that Barnes acted intentionally. The Supreme Court vacated the district court's decision and remanded the case for further proceedings, holding that Utah law recognizing lead poisoning as an occupational disease raises a significant question as to whether the ODA, not the WCA, covered Kay's claim. View "Kay v. Barnes Bullets" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Petitioners' petition for satisfaction of judgment but remanded for correction of a clerical error, holding that Petitioners were not entitled to satisfaction of a judgment.Petitioners were convicted of twelve counts of theft in connection with a real estate deal with entered into with Kerry and Bobbie Posey. As part of a settlement, the Poseys released all civil claims they had against Defendants. In their criminal cases, Petitioners argued that the district court could not base a restitution order on claims for which the Poseys had been remunerated. The district court denied the argument and ordered restitution. The court of appeals affirmed, and the restitution order transformed into a civil judgment. Petitioners then filed a satisfaction of judgment in an effort to extinguish the judgment. The district court denied the petition. The Supreme Court affirmed, holding that the settlement agreement Petitioners entered into with the Poseys did not entitle them to a satisfaction of a judgment. View "State v. Diderickson" on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment to Steven DeConto and Commodity Transporters, Inc. and dismissing John Zilleruelo's complaint alleging negligence, vicarious liability, and negligent entrustment, holding that the district court misinterpreted Utah Code 78B-2-108(2).While Zilleruelo filed his complaint outside the statute of limitations he argued that the accident had rendered him mentally incompetent for one year, and therefore, section 78B-2-108(2) tolled the statute of limitations during the period of his incompetency. The district court granted summary judgment for the defendants, concluding that the statute of limitations had continued to run during the time Zilleruelo claimed he was incompetent. The Supreme Court reversed, holding that the tolling statute does not condition tolling on the lack of a power of attorney or the lack of a legal guardian. View "Zilleruelo v. Commodity Transporters, Inc." on Justia Law

The Supreme Court reversed in part and affirmed in part the restitution order of the district court in connection with Defendant's conviction of theft and theft by deception and otherwise affirmed, holding that litigation expenses incurred in collateral litigation are an appropriate element of restitution under the Crime Victims Restitution Act.On appeal from her conviction and sentence, Defendant challenged the decision to include certain fees in the restitution order and further raised a series of objections to the inclusion of certain electronic transfers in the calculation of the amount of the victims' losses. The State confessed error as to certain transfers, and the court of appeals reversed and remanded for entry of an amended order of restitution but rejected Defendant's other contentions. The Supreme Court remanded to the district court to allow it to enter an amended restitution order excluding the amounts of the four subject transactions but otherwise affirmed, holding that Defendant failed to establish any ground for questioning any of the other electronic transfers in question. View "State v. Sevastopoulos" on Justia Law

In this divorce case, the Supreme Court primarily affirmed in part the decision of the court of appeals reversing the judgment of the district court holding Ronald Rosser in contempt for deliberately deceiving Holly Rosser, holding that the district court's contempt order did not include sufficient findings of fact and conclusions of law to hold Ronald in contempt.In reversing, the court of appeals held (1) Ronald's deceptive conduct did not amount to statutory contempt as a matter of law because it was directed at Holly, rather than at the court; and (2) under Utah Code 78B-6-301(4), deceitful conduct during litigation does not rise to the level of contempt unless it is directed at the court. The Supreme Court affirmed the court of appeals' vacatur of most of the district court's contempt order, holding that the court of appeals (1) correctly reached the interpretation and application of the contempt statute in this case; but (2) erred in reading subsection (4) of the statute to reach only deceit directed at the court because the statute includes deceit in respect to a court's proceedings. View "Rosser v. Rosser" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court compelling arbitration in this suit alleging breach of contract and breach of the covenant of good faith and fair dealing, holding that there was no error.Three doctors, including Lisa Pasquarello and John Artz, formed a limited liability company for their veterinary clinic and adopted an operating agreement that contained an arbitration clause. When Pasquarello tried to sell her portion of the practice to Artz through an oral agreement and the sale failed, Pasquarello brought this lawsuit against Artz. The district court compelled arbitration, concluding that the claims fell under the arbitration clause in the operating agreement. The court of appeals affirmed. The Supreme Court affirmed, holding (1) each of Pasquarello's claims related to the enforcement or interpretation of the operating agreement; and (2) therefore, court of appeals correctly held that the district court properly compelled arbitration. View "Hitorq, LLC v. TCC Veterinary Services, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that compliance with Utah Code 10-2-421 was the only precondition to three cities' taking over service to electric customers in annexed areas of the South Utah Valley Electric Service District (District), holding that the plain text of section 10-2-421 supported the district court's interpretation.Payson City, Spanish Fork City, and Salem City (collectively, Cities) sought to provide electricity to customers in areas that they annexed within the District. The dispute between the Cities and the District was over which statutory provisions governed the requirements the Cities must satisfy in order to take over service to electric customers in annexed portions of the District. The district court ruled in favor of the Cities. The Supreme Court affirmed, holding that the plain language of Utah Code sections 10-2-421 and 10-8-21 sets forth that the Cities may provide electric service to customers inside the district as long as they pay the required reimbursements. View "South Utah Valley Electric v. Payson City" on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment to two job site operators during the 1960s and 1970s for indirectly exposing his wife to asbestos dust, holding that job site operators owe a duty of care to a worker's cohabitants with respect to take-home exposure to asbestos.During his marriage to Barbara Boynton, Larry Boynton worked at numerous job sites where he was exposed to asbestos. Larry alleged in this complaint that Barbara was exposed to asbestos dust he carried home from work, bringing on her mesothelioma and resulting death. The district court granted summary judgment for two job site operators, concluding that they did not owe a duty of care to Barbara. The Supreme Court reversed, holding (1) job site operators are liable to their employees' cohabitants for take-home asbestos exposure; and (2) a genuine issue of material fact existed about whether one of the operators retained control over its contractor. View "Kennecott Utah Copper, LLC v. Phillips 66 Co." on Justia Law

The Supreme Court affirmed the judgment of the district court determining that Gina Kirkland, Garret Heater (Garret), and John Carlon were the heirs to the estate of John Clifford Heater (Heater), holding that the district court did not err in determining that Carlon was an heir.During the ongoing litigation between Garret and Kirkland regarding the administration of Mr. Heater's estate, Carlon intervened, claiming that Heater was his biological father and that he, therefore, was an additional heir the estate. After genetic testing proved Carlon to be Heater's son, the district court entered an order naming Kirkland, Garret, and Carlon as the heirs to Heater's estate. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Carlon established a parent-child relationship with Heater in this case; and (2) the court of appeals did not err in affirming the district court's ruling that Heater was Carlon's natural father and the order naming Carlon as one of Heater's heirs. View "In re Estate of Heater" on Justia Law