Justia Utah Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the district court granting summary judgment in favor of Weber County and dismissing the claims brought by Brian and Mariah Cunningham against the County, a Special Weapons and Tactics training provider, holding that the district court erred across the board.Brian was attending a training when can explosive set on a door latch detonated and caused severe injuries to Brian's face and neck. Brian and Mariah sued the County, alleging negligence and gross negligence. The district court granted the County's motion for summary judgment. The Supreme Court reversed and remanded the action, holding (1) the preinjury release Brian signed was unenforceable because it was neither clear nor unmistakable; and (2) the Governmental Immunity Act of Utah waives immunity for gross negligence claims and loss of consortium claims that arise out of an injury for which immunity has been waived. View "Cunningham v. Weber County" on Justia Law

In this case involving to multiple prosecutions of Defendant for the robbery and theft of a used car the Supreme Court affirmed the judgment of the court of appeals dismissing a subsequent charge against Defendant for aggravated robbery in Weber County, holding that all provisions under Utah's Single Criminal Episode Statute, Utah Code 76-1-401 to -403, were met.The State prosecuted Defendant in Weber County for aggravated robbery after he had already been convicted of theft by receiving in Utah County for conduct arising under the same criminal episode. After the court of appeals dismissed the Weber County charge the State appealed, arguing that Defendant's convictions were not part of a single criminal episode and that the Single Criminal Episode Statute did not apply because the district court in Utah County did not have jurisdiction to hear both offenses. The Supreme Court affirmed, holding that the conviction of Defendant in Utah County for theft by receiving barred the State's subsequent prosecution of Defendant in Weber County for aggravated robbery. View "State v. Sisneros" on Justia Law

In this case arising from the internal breakdown and judicial dissolution of H&N Holdings, LLC the Supreme Court reversed the orders of the district court ordering, sua sponte, the dissolution of H&N, holding that the district court erred.H&N was owned by Dianne Nelson and formerly managed by Vicki's husband, Burke Hills. Dianne filed a lawsuit seeking the dissolution of H&N and the removal of Burke as manager. In lieu of dissolution, H&N and Vicki filed elections to purchase Dianne's membership interest in H&N. The district court dismissed the elections and ordered H&N's dissolution, the removal of Burke as manager, and the appointment of a receiver to liquidate H&N's assets. The Supreme Court reversed, holding (1) H&N made its election as a matter of right, and the district court lacked the power to dismiss the election and order the dissolution of H&N; and (2) the district court violated Vicki's due process rights by ordering H&N's dissolution and Burke's removal as manager without notice or an opportunity to be heard. View "Nelson v. Hills" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Ahhmigo, LLC's motion to vacate the arbitrator's ruling in favor of The Synergy Company of Utah, LLC in this breach of contract proceeding, holding that the district court did not err.Ahhmigo filed a complaint and demand for arbitration against Synergy, alleging breach of contract, unjust enrichment, and other climes. Synergy agreed to arbitrate Ahhmigo's claims, and the arbitrator ruled in favor of Synergy. Ahhmigo moved the district court to vacate the arbitration award, arguing that the arbitrator had manifestly disregarded the law. The district court denied the motion and confirmed the arbitration award. The Supreme Court affirmed, holding that this Court will not reach the question presented on appeal because Ahhmigo did not raise it in the district court. View "Ahhmigo, LLC v. Synergy Co. of Utah, LLC" on Justia Law

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