Justia Utah Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the district court in this case involving a challenge to one party's failure to abide by a provision in the parties' contract, holding that Plaintiff was not entitled to relief. Kiernan Family Draper, LLC (Kiernan) and Hidden Valley Health Center, LC and Hidden Valley, LLC (collectively, Hidden Valley) collaborated to develop their neighboring properties into a shopping center and entered into a declaration of covenants, conditions, and restrictions. At issue was the declaration's statement that a certain number of parking spaces would be provided and the antiwaiver provision stating that a party's failure to enforce a provision of the declaration shall not be construed as a waiver. Fifteen years after Hidden Valley finished construction on its parcel Kiernan sued, challenging Hidden Valley's failure to provide the required parking spaces. The district court applied the statute of limitations to bar Kiernan from enforcing the parking ratio as written in the declaration and in limiting Kiernan's recovery to the post-construction "status quo." The Supreme Court affirmed, holding (1) the declaration's antiwaiver provisions preserved the parking provision despite Kiernan's delay in bringing suit; (2) the statute of limitations barred Kiernan from enforcing the parking provision as written; and (3) Kiernan's claim was subject to the statute of limitations even though it alleged harm to a property right. View "Kiernan Family Draper v. Hidden Valley" on Justia Law

The Supreme Court vacated the determination of the court of appeals that R. Scott National, Inc. (RSN) was an "agent" of Pacific Life Insurance Company (Pacific Life) based on Utah Code 31A-1-301(88)(b), and therefore granting partial summary judgment to Plaintiffs on their claim that Pacific Life should be held liable for RSN's alleged misdeeds, holding that remand was required.The district court granted summary judgment to Pacific Life, concluding that nothing RSN did was within the actual or apparent authority Pacific Life granted RSN. The court of appeals reversed and granted partial summary judgment for Plaintiffs, holding that RSN was Pacific Life's agent and that RSN's actions fell within the scope of authority Pacific Life had granted RSN. The Supreme Court vacated the judgment below, holding that the court of appeals (1) erred in ruling that section 31A-1-301(88)(b) made RSN an agent of Pacific Life and in injecting respondeat superior principles into Utah Code 31A-23a-405(2); and (2) Plaintiffs were entitled to the entry of partial summary judgment on the issue of RSN's apparent authority from Pacific Life. View "Drew v. Pacific Life Insurance Co." on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Petitioner's post-conviction challenge to his convictions of child sex abuse and other offenses as time-barred under the Post-Conviction Remedies Act (PCRA), Utah Code 78B-9-101-503, holding that Petitioner's arguments on appeal were unavailing.Petitioner filed a petition pursuant to the PCRA the district court for post-conviction relief from his criminal conviction and sentence. The district court granted summary judgment for the State, concluding that the petition was time-barred under the PCRA. Petitioner appealed, arguing that the PCRA's time limitations should be tolled or, alternatively, he can invoke the court's constitutional writ power outside the PCRA. The Supreme Court affirmed, holding (1) the PCRA time-barred Petitioner's petition; and (2) Petitioner failed to demonstrate that the application of the time-bar contained in the PCRA to Petitioner's petition violated his rights under the Utah Constitution. View "Patterson v. State" on Justia Law