Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court dismissing Plaintiffs' lawsuit filed against the employer of Kasey Christiansen, who was killed at work, holding that the district court did not err.The district court dismissed Plaintiffs' lawsuit based on a provision of the Workers' Compensation Act that bars employees from suiting their employers over work-related injuries. Plaintiffs appealed, arguing that the district court erred in applying the Act's exclusive remedy provision to dismiss their complaint because the intentional-injury exception applied. The Supreme Court disagreed, holding that Plaintiffs failed to state a claim upon which relief could be granted because it could not reasonably be inferred that Defendant believed Christiansen's fatal injuries were virtually certain to occur. View "Christiansen v. Harrison Western Construction Corp." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the district court's dismissal of Defendant's motion to suppress, holding that there was no error.Testing of a buccal swab of Defendant's cheek showed that Defendant was a genetic match for DNA found on evidence at the scene of a murder. Prior to his criminal trial, Defendant moved to suppress the DNA evidence, arguing that the forcible collection of the sample had violated his Fourth Amendment rights. The district court denied the motion, and a jury convicted Defendant of murder, aggravated burglary, and possession of a weapon by a restricted person. The court of appeals affirmed. The Supreme Court affirmed, holding that the court of appeals did not err in affirming the district court's denial of Defendant's motion to suppress evidence obtained from the buccal swab, nor did it err in rejecting Defendant's statutory arguments. View "State v. Evans" on Justia Law

The Supreme Court vacated the decision of the district court denying Defendant's motion for summary judgment in this lawsuit over a work-related ailment, holding that remand was required.Plaintiff contracted lead poisoning while working for Defendant. A narrow exception in the Workers' Compensation Act (WCA) allows employees like Plaintiff to sue over injuries caused by an employer's intentional act, and Plaintiff sued Defendant under this exception. Defendant filed a motion for summary judgment, arguing that the WCA barred Plaintiff's claim because he did not present sufficient evidence that Defendant acted intentionally. The district court denied the motion. The Supreme Court vacated the decision below, holding (1) although both parties assumed that the WCA covered Plaintiff's condition, Utah law has frequently recognized lead poisoning as an occupational disease governed exclusively by the Occupational Disease Act; and (2) therefore, remand was required to determine if Plaintiff's lead poisoning was an occupational disease. View "Kay v. Bullets" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the district court dismissing Plaintiffs' claims against Intermountain GeoEnvironmental Services, Inc. (IGES), holding that the court of appeals correctly construed the Economic Loss Statute, Utah Code 78B-4-513(1) to (2), to reach Plaintiffs' negligence claims.After moving into their home, Plaintiffs discovered that the walls and foundation were cracking due to "failure surfaces" in the soil approximately sixty-five feet beneath their home. Plaintiffs brought suit against IGES, a geotechnical engineering firm that provided a geotechnical report stating that the site was safe for residential construction, asserting a variety of tort and contract claims. The district court dismissed the claims. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Plaintiffs brought an action for defective design, and therefore, the Economic Loss Statute applied and barred Plaintiffs' negligence claims; and (2) the court of appeals did not err in failing to analyze whether a common law independent duty exception applied to their claims because no common law exception was available. View "Hayes v. Intermountain GeoEnvironmental Services, Inc." on Justia Law

The Supreme Court in this criminal case repudiated the sweeping language of its opinion in State v. James, 13 P.3d 576 (Utah 2000), and held that it can no longer be said that it makes no constitutional difference, as regards community caretaking concerns, whether a police officer opens a car door or asks a driver to do so.Defendant was charged with felony DUI and possession of drugs and drug paraphernalia. Defendant moved to suppress the evidence discovered after an officer looked inside his pickup truck, which was parked in a store parking lot, opened the truck door, and saw evidence of drug paraphernalia between Defendant's feet. The district court denied the motion. The court of appeals affirmed on alternative grounds, holding that the officer was justified in opening the car door incident to a lawful traffic stop under the standard in James. The Supreme Court affirmed, holding (1) the identity of the door-opener may well affect the reasonableness of a given police encounter; and (2) the denial of Defendant's motion to suppress was proper under the authority of Davis v. United States, 564 U.S. 229 (2011). View "State v. Malloy" on Justia Law

The Supreme Court dismissed in part Plaintiff's appeal from the decision of the district court declining to overturn the results of the election for the office of San Juan County Commissioner, holding that Plaintiff lacked standing to file suit.In 2018, Defendant declared that he would run for the office of San Juan County Commissioner. To prove he was a county resident and therefore eligible to run for county offense, Defendant provided coordinates and satellite images for his San Juan County residence. After Defendant won the election, Plaintiff, who was also running for county commissioner, brought this lawsuit arguing that Defendant did not live at the coordinates he provided with his declaration of candidacy. The district court declined to overturn the results of the election. The Supreme Court affirmed, holding (1) Plaintiff lacked standing to file suit because he failed to allege a sufficiently particularized injury; and (2) the district court properly rejected Defendant's cross-appeal for attorney fees. View "Laws v. Grayeyes" on Justia Law

The Supreme Court affirmed Defendant's conviction of dealing in material harmful to a minor, a third degree felony under Utah Code 76-10-1206, holding that Defendant's argument that the statute was unconstitutional as applied failed.As part of a sexually explicit online chat, Defendant sent photographs of women with nude breasts to someone who he thought was an underage girl. Defendant was convicted of dealing in material harmful to a minor, in violation of section 76-10-1206. On appeal, Defendant argued that because the photographs he sent did not depict sexual activity they could not qualify as obscenity, and therefore, the photographs were protected speech under the First Amendment. The Supreme Court affirmed, holding that where nudity may be obscene to minors without depicting sexual conduct, Defendant's argument that the statute was unconstitutional as applied to his conduct failed. View "State v. Watts" on Justia Law

The Supreme Court affirmed Defendant's conviction of distribution of or arranging to distribute a controlled substance, holding that the trial court did not err in denying Defendant's challenge brought under Batson v. Kentucky, 476 U.S. 79 (1986) and that sufficient evidence supported the conviction.On appeal, Defendant argued that the State violated his right to equal protection when it used a peremptory strike to remove the only person of color from the jury pool. The trial court denied Defendant's Batson challenge, and the jury subsequently convicted him of drug-related counts. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's Batson challenge; and (2) there was sufficient evidence to support Defendant's conviction. View "State v. Aziakanou" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of Defendants in this personal injury action, holding that, under the circumstances of this case, Defendants were not negligent.A nine-year-old beginner skier collided with Plaintiff on the "First Time" ski run in Park City. Plaintiff sued the child and her parents, asserting claims for, inter alia, negligence and negligent supervision. The district court granted summary judgment in favor of Defendants. The court of appeals affirmed. The Supreme Court affirmed, holding (1) while a person has a duty to exercise reasonable care while skiing, a nine-year-old beginner skier on a beginner ski run is held to the standard of care commensurate with children of the same age, experience, and intelligence under similar circumstances; and (2) Plaintiff did not carry her burden of showing that Defendants were negligent under the circumstances of this case. View "Donovan v. Sutton" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of driving under the influence, holding that law enforcement officers' touch of Defendant's vehicle was supported by probable cause and provided an independent source of the evidence.Upon responding to a 911 call complaining of a person trying to enter a private residence, two police officers encountered a Ford Explorer that looked to be connected to the disturbance. One officer touched the hood to assess the temperature of the engine in order to determine how long the vehicle had been there. The other officer reached into the wheel well on two occasions, and both officers testified that the engine felt hot. Appellant argued that the officers' testimony about her engine's temperature should have been excluded at trial. The Supreme Court affirmed, holding that, even if the officers' contacts with the vehicle were searches, the automobile exception applied, and the final touch was supported by probable cause. View "State v. Speights" on Justia Law