Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court compelling arbitration in this suit alleging breach of contract and breach of the covenant of good faith and fair dealing, holding that there was no error.Three doctors, including Lisa Pasquarello and John Artz, formed a limited liability company for their veterinary clinic and adopted an operating agreement that contained an arbitration clause. When Pasquarello tried to sell her portion of the practice to Artz through an oral agreement and the sale failed, Pasquarello brought this lawsuit against Artz. The district court compelled arbitration, concluding that the claims fell under the arbitration clause in the operating agreement. The court of appeals affirmed. The Supreme Court affirmed, holding (1) each of Pasquarello's claims related to the enforcement or interpretation of the operating agreement; and (2) therefore, court of appeals correctly held that the district court properly compelled arbitration. View "Hitorq, LLC v. TCC Veterinary Services, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that compliance with Utah Code 10-2-421 was the only precondition to three cities' taking over service to electric customers in annexed areas of the South Utah Valley Electric Service District (District), holding that the plain text of section 10-2-421 supported the district court's interpretation.Payson City, Spanish Fork City, and Salem City (collectively, Cities) sought to provide electricity to customers in areas that they annexed within the District. The dispute between the Cities and the District was over which statutory provisions governed the requirements the Cities must satisfy in order to take over service to electric customers in annexed portions of the District. The district court ruled in favor of the Cities. The Supreme Court affirmed, holding that the plain language of Utah Code sections 10-2-421 and 10-8-21 sets forth that the Cities may provide electric service to customers inside the district as long as they pay the required reimbursements. View "South Utah Valley Electric v. Payson City" on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment to two job site operators during the 1960s and 1970s for indirectly exposing his wife to asbestos dust, holding that job site operators owe a duty of care to a worker's cohabitants with respect to take-home exposure to asbestos.During his marriage to Barbara Boynton, Larry Boynton worked at numerous job sites where he was exposed to asbestos. Larry alleged in this complaint that Barbara was exposed to asbestos dust he carried home from work, bringing on her mesothelioma and resulting death. The district court granted summary judgment for two job site operators, concluding that they did not owe a duty of care to Barbara. The Supreme Court reversed, holding (1) job site operators are liable to their employees' cohabitants for take-home asbestos exposure; and (2) a genuine issue of material fact existed about whether one of the operators retained control over its contractor. View "Kennecott Utah Copper, LLC v. Phillips 66 Co." on Justia Law

The Supreme Court affirmed the judgment of the district court determining that Gina Kirkland, Garret Heater (Garret), and John Carlon were the heirs to the estate of John Clifford Heater (Heater), holding that the district court did not err in determining that Carlon was an heir.During the ongoing litigation between Garret and Kirkland regarding the administration of Mr. Heater's estate, Carlon intervened, claiming that Heater was his biological father and that he, therefore, was an additional heir the estate. After genetic testing proved Carlon to be Heater's son, the district court entered an order naming Kirkland, Garret, and Carlon as the heirs to Heater's estate. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Carlon established a parent-child relationship with Heater in this case; and (2) the court of appeals did not err in affirming the district court's ruling that Heater was Carlon's natural father and the order naming Carlon as one of Heater's heirs. View "In re Estate of Heater" on Justia Law

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