Justia Utah Supreme Court Opinion Summaries

In this case, the defendant was charged in 2022 with two counts of sexual abuse of a child, based on allegations by C.R. that the abuse occurred between 1988 and 1990. During the investigation, C.R. recalled being pulled out of class in seventh grade and questioned about the abuse. The defendant moved to dismiss the charges, arguing that the statute of limitations had expired because C.R.’s communication in seventh grade constituted a report to law enforcement, triggering the limitations period under the statute in effect at the time.The Third District Court for Salt Lake County held an evidentiary hearing on the motion. The State presented testimony from a detective and a records director, but no records of a report from the relevant period were found, and witnesses explained that recordkeeping practices at the time were inconsistent. The defense called former law enforcement officers who testified that not all reports were documented. The district court, relying on the Utah Court of Appeals’ decision in State v. Pierce, concluded that because the evidence was not clear enough to resolve the statute of limitations issue as a matter of law, the question should be submitted to the jury. The court denied the motion to dismiss and reserved the issue for trial.On interlocutory appeal, the Supreme Court of the State of Utah held that the district court erred by reserving the statute of limitations issue for the jury. The Supreme Court clarified that under Utah Code section 76-1-306, the judge—not the jury—must determine by a preponderance of the evidence whether a prosecution is time-barred. The court reversed the district court’s order and remanded the case for the district court to make the necessary factual findings and apply the correct legal standard. The Supreme Court left to the district court’s discretion whether to take additional evidence on remand. View "State v. Smith" on Justia Law

This case arises from a 2004 automobile accident in which one driver, LaMoin Larkin, died. Larkin’s insurer paid benefits to his estate and then sued the surviving driver, Jared Weston, for negligence, also seeking a declaratory judgment that Weston was insured by Farmers Insurance Exchange at the time of the accident. Farmers Insurance Exchange denied coverage, claiming the policy had been cancelled prior to the accident. Weston filed a crossclaim against Farmers, alleging breach of the duty to defend. Weston and Larkin’s insurer arbitrated the negligence claim, resulting in a finding of liability against Weston and a judgment entered in 2009.The Third District Court, Salt Lake County, confirmed the arbitration award and entered judgment. It later held a bench trial to resolve whether Farmers had properly cancelled Weston’s policy, ultimately finding the cancellation was valid and that Weston was not insured at the time of the accident. The court also granted summary judgment that Farmers had breached its duty to defend Weston, as the complaint raised a genuine issue regarding cancellation. Subsequent proceedings addressed damages, including emotional distress and attorney fees. The district court found Weston failed to prove emotional distress caused by the breach and reduced damages to zero. The court also ruled that the 2009 judgment had not expired, allowing it to be amended to include interest and costs.The Utah Court of Appeals affirmed the district court’s findings on cancellation, breach of duty to defend, and emotional distress, but reversed on consequential damages, holding Farmers liable for the arbitration judgment and related attorney fees. On certiorari, the Supreme Court of the State of Utah held that the 2009 judgment expired in 2017 under Utah law, reversing the court of appeals on that issue and vacating the award of damages and attorney fees based on the expired judgment. The Supreme Court affirmed that Farmers breached its duty to defend but found no basis for damages or attorney fees due to the expiration of the judgment. View "Farm Bureau v. Weston" on Justia Law

A Colorado-based company applied to the Utah state engineer for permission to divert 55,000 acre-feet of water annually from the Green River in Utah, intending to pipe it across Wyoming for use in Colorado. The company proposed to use the water along Colorado’s Front Range but had not finalized a delivery location or obtained any approvals from Colorado authorities. The application was subject to both the Upper Colorado River Basin Compact, which governs interstate water allocations, and Utah’s statutes regulating water appropriation and export.After receiving the application, the Utah state engineer published notice, received protests, and held an administrative hearing. The engineer ultimately denied the application, finding that the company had not demonstrated compliance with Utah’s Export Statute, particularly the requirement to show that the water could be beneficially used in Colorado. The engineer also noted the absence of any guarantee from Colorado that the water would be counted against its compact allocation. The company’s request for reconsideration was denied by default. The company then sought de novo review in the Eighth District Court, Daggett County.The district court granted summary judgment for the state engineer, ruling that the Upper Compact did not preempt Utah’s water laws and that the applicant failed to show beneficial use as required by Utah’s Export Statute. The court also found, in the alternative, that Colorado was a necessary and indispensable party that could not be joined. On direct appeal, the Supreme Court of the State of Utah affirmed the district court’s judgment, holding that Utah’s Export Statute is not preempted by the Upper Compact and that the applicant failed to establish a reason to believe the exported water could be beneficially used in Colorado. View "Water Horse v. Wilhelmsen" on Justia Law

A man with severe chronic pain had long been prescribed oxycodone. When he visited his doctor for an unrelated issue, he was also prescribed clonazepam, a benzodiazepine. The combination of these two drugs carries a significant risk of respiratory depression and death, a fact underscored by an FDA-mandated black box warning. The man and his wife expressed concern about the new prescription, but his doctor reassured them. When the prescription for clonazepam was filled at a pharmacy, the pharmacist’s computer system flagged a warning about the dangerous interaction with oxycodone. The pharmacist overrode the warning and dispensed the medication. The man died the next day from toxicity due to both drugs.The man’s family and estate sued the pharmacy, alleging negligence, including a failure to warn about the drug interaction. The Third District Court, Salt Lake County, denied the pharmacy’s motion for summary judgment, which was based on the “learned intermediary rule.” This rule generally exempts pharmacists from warning patients about the general risks of FDA-approved drugs, on the assumption that the prescribing physician is best positioned to provide such warnings. The district court found that there were material factual disputes about whether the pharmacist knew of a patient-specific risk and whether the learned intermediary rule applied.The Supreme Court of the State of Utah reviewed the case on interlocutory appeal. It held that the learned intermediary rule does not shield a pharmacist from liability when the pharmacist is aware of a patient-specific risk, as opposed to general risks associated with a drug. The court affirmed the district court’s denial of summary judgment, clarifying that pharmacists retain a duty to act as a reasonably prudent pharmacist would when aware of such risks. The case was remanded for further proceedings. View "Walgreen v. Jensen" on Justia Law

Two individuals engaged in a recurring scheme to steal merchandise from Walmart. Their method involved purchasing items, then re-entering the store to take identical items without paying, using the original receipt as false proof of purchase if confronted. The stolen goods were then returned to different Walmart locations for cash or gift cards. After being caught, one of the participants pled guilty to two third-degree felonies and admitted that Walmart suffered over $10,000 in damages due to their actions.In the Third District Court, Salt Lake County, the defendant agreed in his plea to pay restitution, suggesting it should be split with his codefendant. At sentencing, he did not dispute the total damages or his responsibility but argued that the restitution should be apportioned equally between him and his codefendant based on comparative fault principles, as he believed both were equally culpable. The district court rejected this argument, holding that precedent from the Utah Court of Appeals required joint and several liability, and ordered both defendants to be responsible for the full amount until it was paid in full.The Utah Supreme Court reviewed whether the Crime Victims Restitution Act allows a sentencing court to apportion restitution among codefendants based on comparative fault, or whether each must be held jointly and severally liable for the damages proximately caused. The court held that the Act requires each defendant to pay restitution for the entire amount of damages proximately caused by their criminal conduct, even if those damages overlap with amounts owed by codefendants. The court concluded that comparative fault apportionment is not permitted under the Act and affirmed the district court’s order imposing joint and several liability for the full restitution amount. View "State v. Debrok" on Justia Law

In this case, Utah voters passed Proposition 4 in 2018, a citizen initiative designed to reform the state’s redistricting process and address partisan gerrymandering. Before the next redistricting cycle, the Utah Legislature repealed Proposition 4 and replaced it with Senate Bill 200 (S.B. 200), which eliminated the key reforms established by the initiative. Several organizations and individuals challenged this legislative action, arguing that the repeal violated Utahns’ constitutional right to alter or reform their government through the initiative process.The Third District Court initially dismissed the plaintiffs’ claim that the Legislature’s repeal of Proposition 4 was unconstitutional. On interlocutory appeal, the Supreme Court of Utah held that the people’s right to reform their government via initiative is constitutionally protected and remanded the case for further proceedings. On remand, the district court granted summary judgment to the plaintiffs, finding that S.B. 200 unconstitutionally impaired the reforms enacted by Proposition 4 and was not narrowly tailored to serve a compelling state interest. The court declared Proposition 4 to be the law, enjoined the use of the 2021 Congressional Map enacted under S.B. 200, and established a remedial process for creating a compliant map. The Legislature’s request to stay the injunction on the 2021 map during the remedial process and any appeals was denied by the district court.The Supreme Court of the State of Utah reviewed the Legislature’s emergency petition for extraordinary relief, which challenged only the district court’s denial of the stay. The Supreme Court held that the Legislature had not shown the district court abused its discretion in denying the stay, as their arguments focused on the remedial process rather than the legal standard for granting a stay. The petition for extraordinary relief was therefore denied. View "State Legislature v. League of Women Voters" on Justia Law

In 1988, a man was convicted of first-degree murder and sentenced to death. Decades later, after exhausting his appeals, he was diagnosed with vascular dementia, a progressive neurocognitive disorder that impairs memory and cognitive function. When the state sought an execution warrant in early 2024, he petitioned the court, arguing that his dementia rendered him incompetent to be executed under the Eighth Amendment, which prohibits executing individuals who cannot rationally understand the reason for their execution.The Third District Court in Salt Lake County held an evidentiary hearing, where multiple experts agreed he had vascular dementia and noted a decline in his cognitive abilities. However, the court found he was still competent to be executed, concluding he could rationally understand the reason for his death sentence. The defendant appealed and requested a stay, which was denied. Subsequently, he filed a new petition for reevaluation, supported by recent expert reports and observations indicating a rapid decline and new inability to understand the connection between his crime and punishment. The district court denied this petition, finding no substantial change in circumstances or significant question about his competency, and issued an execution warrant.The Supreme Court of the State of Utah reviewed the case. It held that, under Utah law, a successive petition to reopen competency proceedings must make a prima facie showing of a substantial change in circumstances and raise a significant question about competency. The court found that the district court erred by weighing rebuttal evidence at the threshold stage and by concluding the new petition did not meet the statutory requirements. The Supreme Court reversed the order denying reevaluation, vacated the execution warrant, and remanded for further proceedings. The appeal of the initial competency order and one extraordinary writ petition were deemed moot. View "State v. Menzies" on Justia Law

A teacher at a public charter school in Utah was terminated after a series of events involving a student and the student's parent. The teacher, a former Air Force veteran, reprimanded the student for disruptive behavior, leading the student to quit the team and report the incident to his father. The parent, dissatisfied with the teacher's conduct, began raising concerns about the teacher's alleged inappropriate behavior, including claims of physical and verbal abuse, to school administrators and at a school board meeting. The parent also communicated these concerns to the school superintendent and, according to the teacher, made a report to local police. Investigations by both the police and the Division of Child and Family Services found no evidence of abuse, and the teacher was ultimately terminated without a stated reason.The teacher filed suit in the Third District Court, Salt Lake County, alleging defamation, intentional infliction of emotional distress (IIED), abuse of process, and tortious interference with economic relations. The parent moved for early dismissal under Utah’s Uniform Public Expression Protection Act (UPEPA), arguing the statute protected his speech and actions. The district court denied the motion, finding UPEPA inapplicable and concluding that the teacher had stated prima facie cases for all claims.On direct appeal, the Supreme Court of the State of Utah held that the district court erred in finding UPEPA did not apply, as the parent’s statements concerned a matter of public concern. The Supreme Court also found that the teacher failed to state prima facie cases for IIED and abuse of process, requiring dismissal of those claims. The court vacated the denial of the special motion as to defamation and tortious interference, remanding for further consideration of whether the teacher could establish a prima facie case, particularly regarding privilege. The court ordered costs and fees related to the motion be awarded as provided by UPEPA. View "Mackey v. Krause" on Justia Law

After the death of Beverly Davies in 2015, her granddaughter filed a petition in the Utah district court to probate Davies’s will just before the three-year anniversary of Davies’s death. The petition sought to have the will declared valid and to appoint the granddaughter as personal representative. However, after nearly three years of inactivity, the court dismissed the petition without prejudice for failure to prosecute. Almost a year after this dismissal, the granddaughter refiled her petition, this time invoking Utah’s Savings Statute, which generally allows a new action to be commenced within one year of a non-merits dismissal if the original action was timely.Davies’s other grandchildren objected to the refiling and moved for partial summary judgment in the Fourth District Court, arguing that the new petition was untimely under Utah Code section 75-3-107, which requires probate proceedings to be commenced within three years of the decedent’s death. They contended that the Savings Statute did not apply to this probate timing statute. The district court disagreed, holding that the Savings Statute protected the granddaughter’s otherwise untimely petition and denied the motion for partial summary judgment.The Supreme Court of the State of Utah reviewed the interlocutory order. The court held that the Savings Statute does not apply to the three-year time limitation in section 75-3-107 of the Utah Uniform Probate Code. The court reasoned that the plain language of the Probate Code prohibits commencing probate proceedings more than three years after death, and this prohibition conflicts with the general grace period provided by the Savings Statute. As a result, the Supreme Court reversed the district court’s denial of partial summary judgment and remanded for further proceedings, concluding that the granddaughter’s second petition was prohibited. View "In re Estate of Davies" on Justia Law

A behavioral healthcare practice employed four therapists who, while still working there, explored job opportunities with another provider. During this process, the prospective employer requested and received information from the therapists, including details about their employment agreements, client lists, and insurance credentialing. The therapists had previously signed confidentiality agreements with their original employer, which defined client information as confidential. After the therapists joined the new provider, a significant number of clients followed them, and the original practice eventually closed.The original employer first sued the therapists for breaching their agreements and settled that case. It then brought a separate lawsuit against the new provider, alleging misappropriation of trade secrets under Utah’s Uniform Trade Secrets Act. The claim centered on the new provider’s alleged use of confidential client information to facilitate onboarding clients, set therapist compensation, and prepare for insurance billing. Both parties moved for summary judgment in the Third District Court, Salt Lake County. The district court granted partial summary judgment to the original employer on liability, finding that trade secrets existed and had been misappropriated, but left damages and exemplary damages for trial. The court denied the new provider’s motion for summary judgment, concluding that the original employer had met its burden of production.The Supreme Court of the State of Utah reviewed the interlocutory order. It held that the original employer failed to present a legally sufficient evidentiary basis for its damages theory, a necessary element of a trade secrets claim. The court found no evidence that the new provider’s receipt of client information caused the original employer’s losses, as clients left primarily to follow their therapists. The court reversed the district court’s denial of summary judgment for the new provider and set aside the partial summary judgment for the original employer. View "Military and Veteran Counseling Center, LLC v. Feller Behavioral Health PLLC" on Justia Law