Justia Utah Supreme Court Opinion Summaries

Randi Mariani crashed her motor scooter and sustained a serious injury during a driving skills test, which she was taking to obtain a motorcycle endorsement to her driver license. Following the crash, the Utah Department of Public Safety-Driver License Division (DLD) denied Mariani’s application for the endorsement. Mariani sued the DLD for negligently causing her injury. The district court granted summary judgment to the DLD based on governmental immunity, and the court of appeals affirmed.The district court concluded that the DLD was immune from Mariani’s suit under the Governmental Immunity Act of Utah (GIA), reasoning that Mariani’s injury arose out of the administration of her motorcycle skills test, which was part of the licensing process. The court of appeals agreed, stating that Mariani’s injury was at least incident to the licensing approval process.The Utah Supreme Court reviewed the case to determine whether the court of appeals erred in affirming the district court’s decision. The Supreme Court focused on the specific language of the GIA’s licensing exception, which provides immunity for injuries that arise out of or in connection with the denial of a license. The Court concluded that the relevant conduct was the denial of the motorcycle endorsement, not the licensing process itself. The Court further determined that there was no causal relationship between the denial of the license and Mariani’s injury, as the injury occurred before the denial. Therefore, the licensing exception did not apply, and the DLD was not immune from Mariani’s suit. The Supreme Court reversed the court of appeals’ decision and remanded the case for further proceedings. View "Mariani v. Driver License Division" on Justia Law

A customer, Davie Montes, purchased a used car from National Buick GMC (National) and signed two agreements: a Purchase Agreement and an Arbitration Agreement. The Purchase Agreement included an integration clause stating it was the complete and exclusive statement of terms. The Arbitration Agreement, which did not have an integration clause, covered disputes related to the purchase or financing of the vehicle. After experiencing issues with the car, Montes sued National, which then moved to compel arbitration based on the Arbitration Agreement.The Fourth District Court in Provo denied National's motion, ruling that the Purchase Agreement's integration clause made it the sole agreement between the parties. The Utah Court of Appeals affirmed this decision, interpreting Utah precedent to mean that the integration clause precluded consideration of the Arbitration Agreement.The Supreme Court of the State of Utah reviewed the case and reversed the lower courts' decisions. The Supreme Court held that contemporaneous, executed agreements related to the same transaction should be construed together, even if one contains an integration clause. The court found that the Purchase Agreement and the Arbitration Agreement were part of the same transaction and should be considered together. The case was remanded for further proceedings consistent with this opinion. View "Montes v. National Buick GMC" on Justia Law

Erik Schnibbe, an attorney, worked at the law firm of Magleby, Cataxinos, and Greenwood. After a client of the firm won a large damages award, the firm paid Schnibbe $1 million for his share of the contingency fee via direct deposit. Schnibbe believed he was promised a greater share and kept the $1 million. Years later, after leaving the firm, he sued for the additional money he claimed he was owed.The Defendants, including the firm and two of its attorneys, moved for summary judgment, arguing that Schnibbe had accepted the $1 million as full settlement of his share of the contingency fee, thus barring his claims under the doctrine of accord and satisfaction. The district court agreed and granted summary judgment to the Defendants.The Utah Court of Appeals affirmed the district court's decision, concluding that all three elements of accord and satisfaction were met: an unliquidated claim or bona fide dispute over the amount due, a payment offered as full settlement of the entire dispute, and acceptance of the payment as full settlement of the dispute. The court focused on the acceptance element, determining that Schnibbe's retention of the $1 million for four years without attempting to return it or registering a protest constituted acceptance of the payment as full settlement.The Utah Supreme Court reviewed the case on certiorari. The court agreed with the lower courts that Schnibbe's conduct indicated acceptance of the payment as full settlement. The court clarified that acceptance could be inferred from the totality of the circumstances, including the creditor's retention of the funds, even if the payment was received passively via direct deposit. The court held that Schnibbe's knowing retention of the $1 million for several years, without attempting to return it, constituted acceptance of the proposed accord as a matter of law. The court affirmed the decision of the court of appeals. View "Magleby v. Schnibbe" on Justia Law

In 2015, Michael Jerry Felts pled guilty to assaulting a police officer and failing to stop at the command of police. The State sought restitution for damage to a police vehicle during the pursuit. The district court referred the restitution question to the Board of Pardons and Parole, which ordered Felts to pay $9,415.28 in June 2021. Felts objected, arguing that insurance had already covered the damage. After legislative amendments in July 2021 removed the Board's authority to issue restitution orders and allowed for judicial review of such orders, Felts contended that the district court could now review the Board's order.The district court held that it lacked jurisdiction to review the Board's restitution order. The Utah Court of Appeals affirmed, stating that the legislative amendments did not retroactively grant district courts the authority to review Board-issued restitution orders. The court of appeals concluded that the amendments were intended to clarify and consolidate restitution authority in district courts moving forward, not to provide retroactive judicial review of past Board decisions.The Utah Supreme Court reviewed the case and affirmed the court of appeals' decision. The Supreme Court held that the legislative amendments did not grant district courts the authority to review restitution orders issued by the Board of Pardons and Parole. The court emphasized that the plain language of the amendments did not support Felts's interpretation and that the removal of the prohibition on judicial review of Board restitution orders was for clarity and consistency, not an independent grant of judicial review. The court also noted that Felts could seek relief through an extraordinary writ under rule 65B of the Utah Rules of Civil Procedure, but he had not pursued that option. View "State v. Felts" on Justia Law

The case involves a dispute over a proposed constitutional amendment in Utah, referred to as Amendment D. The amendment, proposed by the Utah State Legislature, seeks to change the state constitution in three significant ways: specifying that the right to alter or reform the government can only be exercised through constitutional processes, banning foreign influence in the initiative and referendum processes, and granting the Legislature unlimited power to amend or repeal any law passed by a citizen initiative. The controversy centers on whether the amendment was properly submitted to voters and whether it was published as required by the Utah Constitution.The Third Judicial District Court in Salt Lake County reviewed the case and found that the Legislature had not complied with the constitutional requirements for submitting and publishing the proposed amendment. The court ruled that the ballot title for Amendment D was misleading and did not accurately reflect the substance of the amendment, thus failing to meet the Submission Clause of the Utah Constitution. Additionally, the court found that the Legislature did not cause the amendment to be published in newspapers across the state for two months preceding the election, as required by the Publication Clause. Consequently, the district court issued a preliminary injunction declaring Amendment D void and ordered that any votes cast on the amendment not be counted.The Utah Supreme Court reviewed the district court's decision and affirmed the preliminary injunction. The Supreme Court agreed that the ballot title was misleading and did not provide voters with a clear understanding of what they were voting for or against, thus violating the Submission Clause. The Court also held that the Legislature failed to comply with the Publication Clause by not ensuring continuous publication of the amendment's text in newspapers for the required two-month period. The Supreme Court concluded that the district court did not abuse its discretion in finding that the balance of harms and the public interest favored issuing the preliminary injunction. As a result, Amendment D was declared void, and any votes cast on it will have no effect. View "League of Women Voters v. Utah State Legislature" on Justia Law

In 2020, Utah law temporarily allowed municipalities to annex unincorporated areas without a petition or county consent. During this period, the Town of Hideout annexed land in Summit County. After receiving a certificate of annexation from the Lieutenant Governor, Summit County challenged the annexation and the related municipal ordinance in district court, claiming procedural violations and seeking to invalidate the annexation.The Fourth Judicial District Court in Wasatch County ruled in favor of Summit County, granting summary judgment on the grounds that Summit County had standing to challenge the annexation and that the annexation ordinance was invalid due to procedural issues. The court found that Summit County had standing under various statutes and the doctrine of public interest standing.The Utah Supreme Court reviewed the case and reversed the district court's decision. The Supreme Court held that Summit County lacked a legally protectible interest under the relevant statutory scheme, which did not provide counties with a right to challenge annexations. The court also determined that the public interest standing doctrine could not compensate for this lack of a legally protectible interest because the legislature had explicitly excluded counties from the annexation process. Consequently, the Supreme Court directed the district court to dismiss the case. View "Hideout v. Summit County" on Justia Law

In 2021, Derek Willden was charged with multiple counts of physical and sexual assault. During trial preparations, the State requested that Willden disclose certain information under Utah Rule of Criminal Procedure 16(b), specifically audio recordings of interviews conducted by Willden’s counsel with witnesses. Willden objected, claiming the recordings were protected as attorney work product and that compelled disclosure would violate both Rule 16(b)(4) and his constitutional rights. The district court disagreed and ordered Willden to turn over the recordings within thirty days. Willden then sought an interlocutory appeal, which the court of appeals granted, and the case was recalled for direct review.The district court, presided over by the Honorable Elizabeth A. Hruby-Mills of the Third District, Salt Lake County, initially ruled in favor of the State’s discovery motion. The court reasoned that the recordings could be redacted to exclude any attorney’s opinions, analysis, or strategy, thus not constituting protected work product. Willden was given thirty days to comply with the order. Before the deadline, Willden petitioned for an interlocutory appeal, which was granted by the court of appeals, and the case was subsequently recalled for direct review by the Utah Supreme Court.The Utah Supreme Court reviewed the case and focused on the interpretation of Rule 16(b) following its 2021 amendment. The court held that the recorded interviews were indeed attorney work product and thus protected from compelled disclosure under Rule 16(b)(4). The court emphasized that the amended rule explicitly protects attorney work product from disclosure, without distinguishing between "core" and "factual" work product. Consequently, the district court’s order was reversed, and the case was remanded for further proceedings. The court did not address Willden’s constitutional arguments, as the case was resolved based on the interpretation of Rule 16(b). View "State v. Willden" on Justia Law

In this case, Tiffany Bingham challenged the constitutionality of the Utah Health Care Malpractice Act’s four-year statute of repose after her medical malpractice claim against Dr. George C. Gourley and Dr. McKay L. Platt was dismissed. Bingham underwent surgeries in 2010, experienced complications, and discovered in 2017 that the surgeries had caused damage, leading to the removal of her kidney. She filed her lawsuit in 2020, more than four years after the alleged malpractice, prompting the dismissal of her claim under the statute of repose.The Fourth District Court in Provo dismissed Bingham’s complaint, concluding that the statute of repose was constitutional. The court found that the statute did not violate the Open Courts Clause, the Uniform Operation of Laws Provision, or the Equal Protection Clause. The court reasoned that the statute was a non-arbitrary means of addressing the social and economic issues related to rising medical malpractice insurance costs and was reasonably necessary to achieve the legislative goal of stabilizing insurance premiums.The Utah Supreme Court affirmed the lower court’s decision. The court held that Bingham failed to demonstrate that the statute of repose violated the Open Courts Clause, as the legislature’s findings of a health care crisis were fairly debatable and the statute was a reasonable means to address that crisis. The court also found that the statute did not violate the Uniform Operation of Laws Provision, as it was reasonably necessary to achieve the legislative goals and actually and substantially furthered those goals. Finally, the court concluded that the statute did not violate the Equal Protection Clause, as it was rationally related to a legitimate public purpose and did not impair a fundamental right. View "Bingham v. Gourley" on Justia Law

Phil Lyman sought extraordinary relief from the Utah Supreme Court regarding the 2024 primary election for the Utah Republican Party. He requested the court annul the primary election results and certify him as the Republican nominee for Governor in the general election. Lyman argued that the Republican Party’s internal rules should override Utah’s election laws, a claim previously rejected by the court in Utah Republican Party v. Cox. Additionally, Lyman sought the production of voter signatures from nominating petitions and the removal of Lieutenant Governor Deidre Henderson and Governor Spencer Cox from office for alleged malfeasance.The lower courts had not reviewed this case. Lyman filed his petition directly with the Utah Supreme Court, bypassing the district court. He argued that it was impractical to file in the district court due to the urgency of the impending general election deadlines and the long-standing issues surrounding Senate Bill 54, which had been litigated in various courts.The Utah Supreme Court denied Lyman’s petition. The court held that the Republican Party’s internal rules do not override state election laws, reaffirming its decision in Utah Republican Party v. Cox. The court also found that Lyman had not demonstrated why it was impractical to seek relief in the district court and noted that he could not assert claims on behalf of other candidates. Additionally, the court determined that Lyman had not exhausted his administrative remedies under the Government Records Access and Management Act (GRAMA) for his request for voter signatures. Finally, the court found no viable factual or legal basis for Lyman’s request to remove Henderson and Cox from office. Consequently, the court denied Lyman’s petition for extraordinary relief and his related injunction motions as moot. View "Lyman v. Cox" on Justia Law

Colby Jenkins contested the results of the 2024 primary election for the Utah Republican Party candidate for the U.S. House of Representatives in Utah’s Second Congressional District. After a recount, election officials determined that Celeste Maloy had won by a narrow margin. Jenkins challenged the rejection of certain ballots that were deemed untimely because they were not postmarked by the deadline specified in Utah’s election code. He argued that these ballots were mailed before election day but were delayed in receiving a postmark due to variations in U.S. Postal Service practices.The Lieutenant Governor questioned whether Jenkins had the standing to assert constitutional arguments on behalf of the voters whose ballots were not counted. However, the court did not need to decide on this issue because Jenkins failed to establish that he was entitled to the relief he sought. Jenkins argued that the statutory postmark requirement resulted in unequal treatment of voters and interfered with the fundamental right to vote. However, he did not adequately brief these constitutional arguments, failing to cite relevant case law or provide sufficient analysis.The Utah Supreme Court denied Jenkins’s petition for extraordinary relief. The court held that Jenkins did not meet his burden of demonstrating a constitutional violation. Specifically, Jenkins did not show that election officials failed to comply with any statutory mandate, nor did he provide adequate legal support for his claims that the postmark requirement was unconstitutional. The court concluded that voters could ensure their ballots were timely postmarked by mailing them well in advance or by taking them directly to the post office. Therefore, the petition was denied. View "Jenkins v. Beaver County" on Justia Law