Justia Utah Supreme Court Opinion Summaries

In this personal injury action, the Supreme Court affirmed the judgment of the district court granting summary judgment to the United Parcel Service, Inc. (UPS) and concluding that the negligence of KNS International, LLC was a superseding cause of Plaintiff's injury, holding that summary judgment was appropriate.Stuart Wood, a truck driver, was picking up packages from a KNS warehouse when a heavy vinyl curtain fell from the loading bay door above Wood's head and hit him, causing serious injuries. The curtain had been jarred loose after an accident that had occurred one week early when a UPS truck had backed into the loading bay and struck the building. Wood and his wife filed suit against KNS and UPS. The district court granted summary judgment for UPS. The court of appeals affirmed, concluding that UPS owed Wood no duty by the time he was injured. The Supreme Court affirmed on different grounds, holding that summary judgment was appropriate because KNS's actions were a superseding cause of Wood's injury. View "Wood v. United Parcel Service, Inc." on Justia Law

The Supreme Court reversed the interlocutory order of the district court denying Cathy McKitrick's motion to dismiss Kerry Gibson's petition for judicial review of the decision of the Ogden City Records Review Board granting McKitrick's request for government records, holding that a statutory claimant who lacks statutory standing may not proceed on the basis of traditional or alternative standing.McKitrick, a freelance journalist, sought records related to an investigation into the alleged official misconduct by Gibson, a former Weber County Commissioner. After the Review Board granted the records request Gibson petitioned for judicial review. McKitrick filed a motion to dismiss, arguing that Gibson lacked standing under the Utah Governmental Records Access and Management Act to seek judicial review of the appeals board's access decision. In response, Gibson argued that his petition should proceed because he met the tests for both traditional and public interest standing. The district court denied the motion to dismiss. The Supreme Court reversed, holding that a statutory claimant must have statutory standing, and the presence of traditional or alternative standing will not cure a statutory standing deficiency. View "McKitrick v. Gibson" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction of lewdness by a sex offender and vacated the conviction, holding that the court of appeals erred in upholding the district court's admission of other acts evidence.During trial, the State sought to introduce evidence of four prior occasions when Defendant had been accused of exposing and/or stimulating himself in public. The district court admitted the evidence over Defendant's objection, concluding that the doctrine of chances permitted the State to introduce the evidence. The court of appeals affirmed. The Supreme Court reversed, holding (1) if the doctrine of chances is remain part of this jurisprudence, it needs to be more carefully explained and more precisely employed; and (2) the doctrine of chances was not correctly applied to admit the evidence in this case. View "State v. Richins" on Justia Law

The Supreme Court reversed the judgment of the district court ruling that it lacked jurisdiction over this challenge to the rejection of a referendum application, holding that the district court erred in its interpretation of Utah Code 20A-7-602.8(4)(a) and its conclusion that it lacked jurisdiction.Appellants, residents and registered voters of Morgan County, filed an application to submit an ordinance approving the development of a ski resort community to a referendum. The county clerk rejected the referendum application. Appellants then filed in the district court a petition challenging the rejection of the proposed referendum. The district court dismissed the challenge for lack of jurisdiction based on its reading of section 20A-7-602.8(4)(a). The Supreme Court reversed, holding (1) sponsors are prohibited from pursuing an extraordinary writ in the Supreme Court under section 602.8(4)(a) when they cannot satisfy the requirements of Utah R. App. P. 19; and (2) Appellants in this case appropriately raised their challenge in the district court. View "Croft v. Morgan County" on Justia Law

The Supreme Court remanded this case to the district court for further proceedings, holding that, as a matter of law, a boat manufacturer or supplier owes a duty to adequately warn passengers of dangers associated with the failure to wear a stop switch lanyard.Craig Feasel was severely injured when he and the driver of a boat, Monty Martinez, were ejected into the water. Martinez was not wearing the stop switch lanyard at the time of the ejection. Feasel argued that Defendants - the boat manufacturer and the engine manufacturer - were liable for his injuries because they failed adequately to warn the driver of the danger associated with failure to wear the lanyard and failed in their duty to warn boat passengers of the danger. The district court granted summary judgment for Defendants. The court of appeals reversed. The Supreme Court remanded the case, holding (1) the standard for determining the adequacy of a warning is that the warning must be of an intensity and at a level of specificity justified by the magnitude of the risk; and (2) this Court adopts a standard of reasonableness to determine whether warnings regarding the dangers of not wearing a lanyard must be issued directly to the passenger or an intermediary may be relied upon to convey the warnings. View "Feasel v. Tracker Marine LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court denying a wellness company's motion to dismiss this breach of contract action brought by an independent distributor, holding that the distributor's allegation of an express oral waiver was legally sufficient to defeat a motion to dismiss.In its complaint, the distributor claimed that the company had waived - through express oral statements and conduct - the provision upon which it later relied to terminate the distributor's contract. In moving to dismiss the complaint, the company argued that where the contract contained both an antiwaiver provision and a requirement that any waiver be in writing, the distributor's claims were insufficient as a matter of law to waive a provision of the contract. The district court denied the motion to dismiss. The Supreme Court affirmed, holding (1) a contracting party alleging waiver must show the other party intentionally waived both the underlying provision and any applicable antiwaiver provisions; and (2) the alleged facts, taken as true, were sufficient to infer that the company waived the underlying provision and the applicable antiwaiver provisions. View "Al-In Partners, LLC v. LifeVantage Corp." on Justia Law

The Supreme Court affirmed Defendant's conviction of distributing or arranging to distribute a controlled substance, holding that Defendant's trial counsel was not constitutionally deficient in not requesting a jury instruction pursuant to State v. Long, 721 P.2d 483 (Utah 1986), about the potential unreliability of eyewitness identification.During trial, Defendant's counsel presented a theory of mistaken identification in his opening and closing arguments and cross-examined the prosecution's witnesses about weaknesses in their testimony. On appeal, Defendant argued that his trial counsel's failure to request a Long instruction constituted ineffective assistance of counsel. The court of appeals affirmed, concluding that Long does not apply to "real-time identifications," such as the identification in this case. The Supreme Court vacated the court of appeals' holding that Long did not apply but nevertheless affirmed, holding (1) the court of appeals erred when it ruled that Long applies only to "memory-based" identifications; and (2) a reasonable, competent lawyer could have chosen not to request a Long instruction in this case. View "State v. Hunter" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claims against the University of Utah for breach of contract, breach of the covenant of good faith and fair dealing, and negligence, holding that Plaintiff did not identify a basis for a legal cause of action against the University.After the University dismissed Plaintiff from its neuroscience Ph.D. program, and the decision was affirmed at every level of administrative review, Plaintiff brought his action against the University. The district court dismissed all claims on summary judgment. The Supreme Court affirmed, holding (1) as to Plaintiff's breach of contract claims, the University was entitled to judgment as a matter of law; (2) Plaintiff's claims for breach of the covenant of good faith and fair dealing failed; and (3) the district court correctly dismissed Plaintiff's negligence claim. View "Rossi v. University of Utah" on Justia Law

The Supreme Court vacated Defendant's conviction of accomplice to aggravated robbery, a first degree felony, under a theory of accomplice liability, holding that the trial court gave an erroneous mens rea instruction to which trial counsel should have objected and this failure to object prejudiced Defendant.At issue was a jury instruction detailing the mens rea required to convict under an accomplice-liability theory. On appeal, Defendant argued that the jury instruction was erroneous and that trial counsel was deficient in failing to object to it. The court of appeals affirmed the conviction, concluding that the instructions adequately instructed the jury on accomplice liability for aggravated robbery. The Supreme Court reversed, holding (1) the jury instruction at issue was erroneous and that trial counsel performed deficiently in failing to object to it; and (2) trial counsel's deficient performance prejudiced Defendant. View "State v. Eyre" on Justia Law

In this case alleging that Larry Boynton's wife, Barbara, was exposed to asbestos dust from several job sites that Larry worked at during the 1960s and 1970s, the Supreme Court reversed the order of the district court granting summary judgment to the job site operators, holding that premises operators owe a duty of care to a worker's cohabitants with respect to take-home exposure to asbestos.During his marriage to Barbara, Larry worked at numerous job sites where he was exposed to asbestos. In 2016, Barbara was diagnosed with Malignant mesothelioma and died from it that year. Larry sued the job site operators for indirectly exposing Barbara to asbestos dust. The district court granted summary judgment in favor of two of the operators, concluding that they had no duty to prevent "take-home exposure" to asbestos dust. The Supreme Court reversed, holding (1) premises owners are liable to their employees' co-habitants for take-home asbestos exposure; and (2) a genuine issue of material fact existed as to whether one of the premises operators retained control over its contractor. View "Kennecott Utah Copper, LLC v. Phillips 66 Co." on Justia Law