Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying doTERRA International, LLC's motion for partial summary judgment asserting that Jessica Kruger, who sought, among other things, punitive damages based on doTERRA's failure to warn about the potential dangers of its product, waived the right to seek punitive damages, holding that the trial court correctly denied doTERRA's motion for summary judgment.Kruger, a doTERRA International, LLC distributor, applied a doTERRA product to her skin before visiting a tanning salon and was later diagnosed with second and third-degree chemical burns. doTERRA filed a motion for summary judgment, arguing that Kruger was contractually restricted from seeking punitive damages because she had waived her ability to claim punitive damages in the agreement she signed to become a doTERRA distributor. The Supreme Court affirmed but vacated the district court's reference to doTERRA's contract as one of adhesion, holding that because the waiver in doTERRA's agreement was neither clear nor unambiguous Kruger did not waive her right to sue doTERRA for punitive damages arising out of a personal injury. View "doTERRA v. Kruger" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Shree Ganesh, LLC's contract and tort claims against Weston Logan, Inc., and Matthew Weston, an individual, holding that there remained a genuine dispute as to material facts, precluding summary judgment.Shree Ganesh entered into a contract with Weston Logan to purchase Weston Logan's Best Western Inn. After the sale of the property closed, Shree Ganesh learned about Weston Logan's plans to build a competing hotel across the street. Shree Ganesh subsequently sued Weston Logan for its failure to disclose its plans to develop the competing hotel. The district court granted summary judgment in favor of Weston Logan on all claims. The Supreme Court reversed, holding (1) the purchase agreement was ambiguous as to Weston Logan's disclosure obligations; and (2) there remained a genuine dispute as to material facts relevant to Shree Ganesh's tort claims. View "Shree Ganesh, LLC v. Weston Logan, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that the divorce decree at issue included provisions that, taken as a whole, could be interpreted to suggest that the parties contemplated that alimony would continue upon remarriage, holding that the presumption that alimony terminates upon remarriage was not rebutted in this case.Melvin and Janette McQuarrie divorced in 2008. The district court entered a divorce decree detailing the terms of their mediated stipulation for divorce, under which Melvin was required to pay alimony to Janette. The alimony provisions of the decree did not explicitly address the effect of Janette's remarriage. After Janette remarried, Melvin filed a petition to modify the parties decree, asserting that the remarriage justified a termination of the alimony obligation. The district court denied the motion, holding that the decree language specifically provided that the alimony/child support payments would continue beyond remarriage. The court of appeals affirmed. The Supreme Court reversed, holding that because there was no specific, express provision in the decree that alimony would continue upon remarriage, Melvin's alimony obligation terminated by operation of law. View "McQuarrie v. McQuarrie" on Justia Law

The Supreme Court affirmed the judgment of the juvenile court terminating Mother and Father's parental rights based on years of dysfunctionality, substance abuse, and criminal conduct, holding that the juvenile court did not err.Specifically, the Supreme Court held (1) the juvenile court did not err in declining to apply the "beyond a reasonable doubt" standard of proof, and this Court declines to adopt that standard now; (2) the juvenile court did not err by concluding that termination was strictly necessary and in the children's best interests; and (3) Parents did not carry their burden to brief the issue of whether the court erred in considering a provision from the Human Services Code in its analysis. View "In re G.D." on Justia Law

In this appeal from the entry of a final order of adoption the Supreme Court reversed the entry of summary judgment against the child's putative father, J.S.P., holding that the district court erred in dismissing J.S.P. from the adoption action.J.S.P. sought to intervene in the adoption on the ground that he was the presumed father of the child because the child had been born during his attempted marriage with the child's mother, K.C. The district court granted the motion to intervene but later dismissed J.S.P. on a motion for partial summary judgment, holding that J.S.P. was not the presumed father because his marriage to K.C. was invalid. The adoption action went forward, resulting in a final order of adoption. The Supreme Court reversed, holding (1) the decision on partial summary judgment was not final, and accordingly, this Court had appellate jurisdiction; and (2) the district court erred in dismissing J.S.P. because his marriage to K.C., while legally invalid, was entered into in apparent compliance with the law, and the child was born during the invalid marriage and before any events that would have terminated the marriage. View "In re Adoption of C.C." on Justia Law

The Supreme Court vacated the decision of the district court concluding that the adjudication of Plaintiff's intentional infliction of emotional distress claim against a church must be dismissed on the grounds that the adjudication of this claim would violate the Establishment Clause of the First Amendment, holding that recent changes in the Supreme Court's Establishment Clause jurisprudence required further development of the facts and legal arguments presented in this case.Plaintiff and her family attended the Roy Congregation of the Jehovah's Witnesses Church. When Plaintiff was sexually assaulted by another Jehovah's Witnesses congregant the Church investigated Plaintiff to determine whether she had engaged in the sin of "porneia." During the investigation, four Elders in the Church convened a disciplinary hearing in which they played an audio recording of the other congregant raping Plaintiff. Plaintiff then filed her complaint against the Church for intentional or negligent infliction of emotional distress. The district court dismissed the complaint, concluding that the Establishment Clause barred the claim. The Supreme Court vacated the district court's decision, holding that because the district court relied on a test that has recently been displaced by the Supreme Court, the case must be remanded for additional proceedings. View "Williams v. Kingdom Hall of Jehovah's Witnesses" on Justia Law

In this civil action for reimbursement of attorney fees incurred in the successful defense of criminal charges the Supreme Court held that Utah Code 52-6-201 did not require Bret Rawson P.C. to subtract a donation made from a legal defense fund in calculating "reasonable attorney fees and court costs."Defendant, a West Valley City police officer, was charged with manslaughter arising out of conduct in the line of duty. After a preliminary hearing, the charge was dismissed. Defendant assigned his claim to a right of reimbursement of his attorney fees to Rawson. Rawson then filed this action seeking reimbursement of reasonable attorney fees under section 52-6-201. West Valley City filed a motion asserting that the amount of available fees was limited in two ways. The district court denied the motion. The Supreme Court affirmed in part and remanded, holding (1) the district court properly found that a $60,000 donation by a legal defense fund should not be subtracted from the total amount of fees "necessarily incurred" in the defense of the charge against Defendant; and (2) as to the City's argument that the amount of fees "necessarily incurred" was capped by a flat fee agreement entered into between Defendant's defense team and his counsel, the case must be remanded for further proceedings. View "West Valley City v. Rawson" on Justia Law

The Supreme Court affirmed the judgment of the district court awarding Appellees attorney fees pursuant to a provision of a contract under which they sued, holding that the claim for contractual attorney fees was governed in this case by Georgia law.The contract at issue in this case contained a choice of law provision requiring contractual disputes to be governed by Georgia law. Appellants sued Appellees in Utah, alleging breach of contract. Appellees moved to dismiss. The district court granted the motion. Appellees then filed a motion seeking recovery of attorney fees. In response, Appellants argued that Georgia law should govern the attorney fee provision just as it did the rest of the contract. The district court granted the motion, concluding that Appellees were entitled to attorney fees under the law of either jurisdiction. The Supreme Court affirmed, holding (1) the matter of contractual attorney fees is substantive for choice of law purposes; and (2) applying Georgia law, Appellants failed to show that the district court erred in awarding Appellees attorney fees. View "1600 Barberry Lane 8 LLC v. Cottonwood Residential L.P." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the district court finding Yvonne Martin in unlawful detainer and entering a judgment that included a substantial award, holding that the court of appeals did not err.Upon her divorce from Petter Kristensen, the divorce court awarded Yvonne temporary possession of the marital home - which was owned by Petter's father, Frank - during the pendency of the divorce proceedings. After Yvonne filed for divorce Frank served her with a notice to vacate. Yvonne refused to vacate, and Frank filed an unlawful detainer action against her. A jury concluded that Frank was the rightful owner of the property and that Yvonne was guilty of unlawful detainer starting five days after Frank filed the notice to vacate. On appeal, Yvonne argued that the temporary possession order precluded Frank from seeking the remedies available in an unlawful detainer action. The court of appeals affirmed. The Supreme Court affirmed, holding that the possession orders in the divorce proceeding functioned like a temporary possession order in an unlawful detainer proceeding in that they precluded Yvonne's eviction from the property but did not affect the availability of statutory remedies for unlawful detainer. View "Martin v. Kristensen" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the denial of post conviction relief sought by Defendant, holding that Defendant's claims failed.Defendant was convicted of sexually molesting his daughter. The convictions were affirmed on appeal. Defendant then filed a petition for post-conviction relief, asserting ineffective assistance of counsel. The reviewing court concluded that the Post-Conviction Remedies Act (PCRA), Utah Code 78B-9-101-110, barred Defendant's claims of ineffective assistance of trial counsel but allowed Defendant's ineffective assistance of appellate counsel claims to proceed. The court then denied relief. On appeal, the court of appeals held (1) the PCRA barred Defendant's "direct" claims, and (2) appellate counsel was de facto not ineffective. The Supreme Court affirmed, holding (1) the PRCA barred Defendant's direct claims against his trial counsel; and (2) Defendant's ineffective assistance of appellate counsel claims were without merit. View "McCloud v. State" on Justia Law