Justia Utah Supreme Court Opinion Summaries

The Supreme Court held that the equitable estoppel doctrine offers a discrete basis for tolling a statute of limitations in Utah.Owners executed a trust deed note with Alpine East Investors, LLC for certain property and promised to pay the note in full within two years. The promise was not fulfilled. After the foreclosure limitations period had expired, Owners sought to enjoin Alpine East from foreclosing its trust deed on the property and a determination that Alpine East had no valid interest in the property. Alpine East invoked the doctrine of equitable estoppel seeking to toll the limitations period. Owners argued that equitable estoppel is not a stand-alone basis for defeating a statute of limitations defense. The district court granted summary judgment for Owners, declaring that the limitations period for enforcing the trust deed had expired before Alpine East recorded a notice of default or filed an action to foreclose. Thereafter, the court granted Alpine East's Rule 59 motion to revise the ruling, concluding that findings of fact existed precluding summary judgment. The Supreme Court vacated the judgment of the district court, holding (1) equitable estoppel is a discrete basis for tolling a statute of limitations; but (2) a mere promise to pay, without more, is insufficient to invoke equitable estoppel. View "Fitzgerald v. Spearhead Investments, LLC" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court convicting Defendant of two counts of sexual battery, holding that the victim's testimony was materially consistent and sufficient to support Defendant's conviction.Defendant's conviction was based primarily on testimony from the victim. On appeal, Defendant argued that the victim's testimony was so inherently improbable that it could not support a finding of guilt. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a defendant does not need to raise a sufficiency of the evidence claim at a bench trial to preserve the issue for appeal; and (2) the victim's testimony was far from inherently improbable but was, rather, overwhelmingly and materially consistent and sufficient to support a conviction. View "State v. Jok" on Justia Law

The Supreme Court reversed the district court granting Defendant's renewed motion for judgment as a matter of law and vacating the jury's general damages verdict in favor of Plaintiff on her negligence claim, holding that the district court erred.Plaintiff's vehicle was hit by a truck by a driver that worked for Geneva Rock. Plaintiff sued the driver and Geneva Rock, alleging that the driver's negligence caused the crash and that Geneva Rock had negligently employed the driver. Geneva Rock conceded that its driver was at fault for the collision. After Plaintiff rested her case-in-chief during a trial on the issue of damages, the court ruled that the jury could not award special damages to Plaintiff for lack of sufficient evidence. The jury returned a general damages verdict of $30,000. The district court vacated the jury's verdict, concluding that Plaintiff failed to produce sufficient evidence to meet the requirements of Utah Code 31A-22-309. The Supreme Court reversed and remanded the case, holding (1) Plaintiff was entitled to ask the jury to award special damages; and (2) the district court improperly excluded evidence of Geneva Rock's negligent hiring practices. View "Sheppard v. Geneva Rock" on Justia Law

The Supreme Court vacated Defendant's sentence for aggravated kidnapping and aggravated sexual assault and remanded with resentencing instructions to merge the two charges and affirmed his convictions, holding that Defendant's remaining claims of error were unavailing.Specifically, the Supreme Court held (1) the district court did not err when it allowed a recording of Defendant's police interview to go back to the jury room during deliberations; (2) Defendant's trial counsel was not ineffective for agreeing to the jury instruction defining "attempt" or for failing to make an unfair prejudice objection to a jail officer's testimony; and (3) the trial court should have merged the charges of aggravated kidnapping and aggravated sexual assault because the same acts satisfied the elements of each charge. View "State v. Wyatt" on Justia Law

The Supreme Court reversed the judgment of the district court granting judgment on the pleadings in favor of Nebo School District on Plaintiff's negligent employment claim, holding that the district court erred in dismissing Plaintiff's negligent employment claim.A school bus operated by a driver employed by Nebo School District caused a crash with Plaintiff. In his complaint, Plaintiff claimed that Nebo was liable for its driver's negligence under principles of respondent superior and that Nebo was independently negligent because it continued to employ the driver even though he had been involved in several accidents. Nebo moved for judgment on the pleadings, arguing that the negligent employment claim was redundant with the negligence claim and that Plaintiff was not entitled to pursue a claim directly against it after it conceded vicarious liability. The district court granted the motion. The Supreme Court reversed, holding that the district court (1) did not abuse its discretion when it found that Nebo's motion for judgment on the pleadings was timely; and (2) Plaintiff was entitled to proceed on alternate claims. View "Ramon v. Nebo School District" on Justia Law

The Supreme Court reversed in part and vacated in part the judgment of the district court denying Plaintiff's request for a civil stalking injunction against Defendant, holding that the district court erred.Plaintiff ran a residential treatment program for young woman. Defendant, her neighbor, objected to the program's presence in his neighborhood and flipped off and swore at Plaintiff and the program attendees and placed provocative signs in his yard. Plaintiff sought a civil talking injunction, which the district court denied. The Supreme Court reversed in part and vacated in part, holding (1) the district court misinterpreted the stalking statute; (2) the district court failed to assess the impact of Defendant's conduct on a reasonable person in Plaintiff's circumstances; (3) the district court applied an incorrect analysis in deciding that the First Amendment protected Defendant's conduct; and (4) because the reversal of the first three issues may affect the basis for the district court's attorney-fees decision, that decision is vacated, and the matter is remanded for a new determination. View "Ragsdale v. Fishler" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing on summary disposition the denial of Appellant's appeal from the denial of unemployment benefits, holding that following the plain language of Utah Code 35A-4-403 in requiring a claimant who has obtained a work-search deferral to be nonetheless able and available to accept full-time employment does not produce an absurd result.Appellant sought unemployment benefits after he was temporarily laid off from his job. The Department of Workforce Services denied benefits because Appellant had indicated on his application that he was unavailable to accept full-time work because he would be returning to his former employer. The Department deferred the requirement that Appellant actively seek employment while receiving benefits but still required him to be able and available to accept full-time work under section 35A-4-403. The ALJ and the workforce appeals board denied Appellant's appeal. The court of appeals reversed, concluding that interpreting the statute to require a claimant who had obtained a work-search deferral to nonetheless be able and available to accept full-time employment worked an absurd result. The Supreme Court reversed, holding that the Department properly denied Appellant's claim for unemployment. View "Arnold v. Department of Workforce Services" on Justia Law

The Supreme Court answered a certified question posed by the United States Court of Appeals for the Tenth Circuit regarding the reach of the Utah Health Care Malpractice Act (Act), Utah Code 78B-3-401 through 426, by concluding that the Act applied in this case involving an injury sustained while climbing a rock formation during a "wilderness therapy" excursion.Jacob Scott sued Wingate Wilderness Therapy, LLC seeking relief for injuries he sustained as a minor while rock climbing during a wilderness therapy hiking excursion. The federal district court granted Wingate's motion to dismiss, concluding that the Act applied to Scott's claims and that Scott (1) failed to file his action within the two-year statute of limitations, and (2) failed to comply with the Act's procedural requirements. Scott appealed, arguing that the district court erred in finding that his injuries arose out of the health care provided by Wingate. The circuit court certified a question to the Utah Supreme Court, which answered by holding that, under the circumstances of this case, the Act applied to Scott's claims. View "Scott v. Wingate Wilderness Therapy, LLC" on Justia Law

In this case in which in which a sales representative of Alarm Protection Technology (APT) sought to challenge a set of steps taken by APT to insulate itself from claims for unpaid compensation, the Supreme Court held that the district court did not err in denying a motion filed by Plaintiff.Plaintiff, a former sales representative for APT, filed an action alleging that APT and related parties owed him $348,434 in unpaid commissions. This appeal concerned steps taken by APT to insulate itself, including its payment of an advance in exchange for the execution of a confession of judgment, the entry of a judgment by confession, the issuance of a writ of execution against Plaintiff's claims for unpaid commissions, APT's subsequent purchase of those claims, and APT's substitution as plaintiff on the claims against itself. At issue were the district court's denial of Plaintiff's motion for return of excess proceeds and unused property from APT's purchase of his claims. The Supreme Court affirmed, holding that APT was not required to (1) establish the value of Plaintiff's claims before executing on them and purchasing them, (2) presume that the true value of the claims was established in the allegations of Plaintiff's complaint, and (3) return to Plaintiff exceeds proceeds or remaining property on the basis of those allegations. View "Alarm Protection Technology, LLC v. Bradburn" on Justia Law

In this case in which a sales representative of Alarm Protection Technology (APT) sought to challenge a set of steps taken by APT to insulate itself from claims for unpaid compensation, the Supreme Court held that the district court did not err in denying two motions filed by Plaintiff.Plaintiff, a former sales representative for APT, filed an action alleging that APT and related parties owed him $143,000 in treble damages for unpaid commissions. This appeal concerned APT's payment of an advance in exchange for the execution of a confession of judgment, the entry of a judgment by confession, the issuance of a writ of execution against Plaintiff's claims for unpaid commissions, APT's subsequent purchase of those claims, and APT's substitution as plaintiff. Plaintiff specifically appealed the denial of his motion to vacate the judgment by confession and quash the writ of execution of his claims and his motion for return of excess proceeds and unused property from APT's purchase of his claims. The Supreme Court affirmed, holding that APT was not required to (1) establish the value of Plaintiff's claims before executing on them and purchasing them, (2) presume that the true value of the claims was established in the allegations of Plaintiff's complaint, and (3) return to Plaintiff exceeds proceeds or remaining property on the basis of those allegations. View "Alarm Protection v. Crandall" on Justia Law