Justia Utah Supreme Court Opinion Summaries

The Supreme Court held that the strict compliance requirement of section 110 of Utah's Adoption Act, which permits a district court to terminate parental rights if the parent does not "fully and strictly comply" with the statutory requirements, as applied to Mother, is not narrowly tailored to achieve the State's compelling interest in prompt adoption proceedings.Mother gave birth to Child in 2010. Sometime thereafter, Child went to live with Adoptive Parents. In 2015, Adoptive Parents filed an adoption petition and served notice of the proceeding on Mother. The notice informed Mother that she had thirty days to file a motion to intervene or she would forfeit her parental rights in Child and would be barred from participating in the adoption proceeding. Mother attempted to intervene, but the district court struck her filing due to a procedural deficiency in the document and barred her from participating in the adoption proceeding. Mother filed a Utah R. Civ. P. 60(b) motion seeking relief from the order to strike, which district court denied. The Supreme Court reversed, holding that Mother's substantive due process rights were violated because section 110's strict compliance requirement is not narrowly tailored. View "In re K.T.B." on Justia Law

The Supreme Court affirmed Defendant's sentence of life in prison without the possibility of parole for aggravated murder, holding that Defendant was not entitled to a new penalty-phase trial.Specifically, the Supreme Court held (1) even if Defendant's trial counsel rendered ineffective assistance, Defendant was not prejudiced by that deficiency; (2) any error in admitting certain hearsay statements during trial was harmless beyond a reasonable doubt; (3) Defendant was not prejudiced by victim-impact evidence; (4) the trial court did not abuse its discretion by refusing to give a beyond-a-reasonable-doubt jury instruction under State v. Lafferty, 749 P.2d 1239 (Utah 1988); and (5) Defendant inadequately briefed his argument under the doctrine of cumulative error. View "State v. Drommond" on Justia Law

In this criminal case, the Supreme Court reversed the ruling of the court of appeals that the trial court erred in admitting the testimony of the State's expert witness, holding that the court of appeals conflated the requirements and remedies of the Expert Notice Statute, Utah Code 77-17-13, and Utah R. Evid. 702 and in shifting the burden to the State to disprove prejudice.The court of appeals vacated Defendant's convictions of four counts of sodomy on a trial, holding (1) the trial court committed reversible error in allowing the State's expert witness to testify in violation of Rule 702; and (2) the State did not meet its burden to prove that Defendant had not been prejudiced by the denial of his motion for a continuance. The Supreme Court reversed, holding (1) the court of appeals' Rule 702 analysis was erroneous; and (2) the court of appeals erred in shifting the burden to the State to disprove prejudice. View "State v. Peraza" on Justia Law

The Supreme Court reversed the determination of the district court that a contract entered into by a dissolved partnership was void, holding that the contract was voidable.Two years after the Muir Second Family Limited Partnership was administratively dissolved, the former general partner of the partnership - Nicholas Muir - obtained a loan from the TNE Limited Partnership through a trust deed. Wittingham, LLC, a successor-in-interest to the Partnership, brought suit to declare the trust deed void and recover damages. The district court concluded that the trust deed was void because the Partnership was dissolved prior to the time Muir signed the trust deed. The Supreme Court reversed, holding that the trust deed was voidable because the relevant statutes failed to provide a clear and well-defined public policy indicating that the type of transaction here should be void and because the transaction deed did not harm the public as a whole. View "Wittingham v. TNE Limited Partnership" on Justia Law

The Supreme Court largely affirmed the decision of the court of appeals affirming Defendant's convictions of violating a protective order, aggravated sexual assault relating to rape and digital penetration, kidnapping, burglary, and assault but held that the district court erred in refusing to instruct on sexual battery as a lesser included offense of aggravated sexual assault based on forcible sexual abuse.Specifically, the Supreme Court held that the court of appeals (1) did not err in concluding that any error in the jury instructions on aggravated sexual assault, rape, and forcible sexual abuse did not prejudice Defendant; (2) did not err in affirming the district court's refusal to instruct the jury on additional lesser included offenses of aggravated sexual assault based on rape, aggravated burglary, and aggravated kidnapping but erred in affirming the district court's refusal to instruct on sexual battery as a lesser included offense of aggravated sexual assault based on forcible sexual abuse; (3) did not err in affirming the district court’s sentence of fifteen years to life on both convictions of aggravated sexual assault; (4) did not err in concluding that the district court conducted a proper interests of justice analysis at sentencing; and (5) did not err in rejecting Norton’s claim of cumulative error.` View "State v. Norton" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the judgment of the district court against Rocky Ford Irrigation Company on its lawsuit against Kents Lake Reservoir Company seeking clarification regarding the priority of the parties' rights and Kents Lake's obligations as to the Beaver River administration and measurement, holding that the district court erred in denying Rocky Ford's motion for summary judgment.Specifically, the Supreme Court (1) reversed the district court's denial of Rocky Ford's motion for summary judgment, holding that Rocky Ford was entitled to judgment as a matter of law on the second point on which it sought a declaration of rights; (2) affirmed the court's decision refusing to declare that Kents Lake could not store its efficiency gains; (3) reversed the court's denial of Rocky Ford's request for declaratory judgment as to Kents Lake's measurement obligations under a 1931 Beaver River Decree, holding that the clarification Rocky Ford sought was warranted; (4) affirmed the court's decision refusing to rescind the agreement entered into by the parties in 1953; and (5) reversed the decision awarding attorney fees to Kents Lake and Beaver City, holding that there was no basis for a determination that Rocky Ford filed or pursued its claims in bad faith. View "Rocky Ford Irrigation Co. v. Kents Lake Reservoir Co." on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for being an accomplice to the crime of aggravated murder, holding that it was reasonably probable that the jury would not have convicted Defendant of aggravated murder absent jury instruction errors.After Defendant was convicted she appealed, arguing that her trial counsel was ineffective for failing to object to three errors in the jury instruction regarding accomplice liability. The court of appeals concluded that there were three errors in the jury instruction and that the performance of Defendant's trial counsel was deficient because he did not object to the errors. However, the court of appeals determined that the errors were not prejudicial because there was not a reasonable probability of a more favorable outcome absent the errors. The Supreme Court reversed and remanded the case for a new trial, holding (1) the jury instruction discussing the elements for accomplice liability on aggravated murder contained three errors; and (2) there was a reasonable probability that at least one juror would not have voted to convict Defendant in the absence of the errors. View "State v. Grunwald" on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant's expungement petition, holding that the district court did not abuse its discretion in denying the petition.Appellant was charged with one count of unlawful sexual conduct with a sixteen or seventeen year old. Before trial, because the complaining witness was unavailable for trial, the district court granted the State's motion to dismiss the case without prejudice. Seven months later, Appellant filed his expungement petition. The district court denied the petition on the basis that Appellant had failed to establish by clear and convincing evidence that his expungement was not be contrary to the public interests. The Supreme Court affirmed, holding that the district court did not err in the way it handled the matter or in its decision to deny Appellant's expungement petition. View "State v. Malo" on Justia Law

In this automobile accident case, the Supreme Court affirmed the decision of the court of appeals affirming the district court's general-damages award granted to Plaintiff, holding that Plaintiff satisfied the requirements of Utah Code 31A-22-309 and that the district court correctly denied Defendant's new trial motion.On appeal, Defendant argued (1) Plaintiff failed to satisfy the requirements set forth in section 31A-22-309, a prerequisite to receiving general damages in most automobile accident cases, because Plaintiff did not show that she sustained a "permanent disability or permanent impairment based upon objective findings"; and (2) under Utah R. Civ. P. 59, a new trial on the amount of damages should be granted because the award of general damages Plaintiff was awarded was excessively disproportionate to the economic damages awarded. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the court of appeals did not err in interpreting the phrase "objective findings"; and (2) the court of appeals did not err in affirming Plaintiff's damage award because the award was supported by sufficient evidence and was not so excessive as to appear to have been given under the influence of passion or prejudice. View "Pinney v. Carrera" on Justia Law

In this appeal arising from a dispute between lien holders regarding the distribution of the money a foreclosure sale of Zermatt Resort had generated the Supreme Court vacated the decision of the court of appeals concluding that it had jurisdiction to resolve a procedural matter and affirming the district court, holding that the court of appeals did not have jurisdiction to resolve the matter.After the district court entered its final judgment in this matter but before the time to appeal expired Trapnell & Associates, LLC purchase the plaintiff's interest in the litigation. Trapnell filed a notice under Utah R. Civ. P. 17 that it was a real party in interest and, on that same day, lodged a notice of appeal. The court of appeals noted that it would have been better had Trapnell filed a motion invoking Utah R. Civ. P. 25(c) instead of a notice invoking rule 17 but ruled on the merits of Trapnell's arguments, concluding that because Trapnell had intended to become a party and the district court had treated Trapnell as a party, Trapnell had become a party. The Supreme Court vacated the court of appeals' decision, holding that the court of appeals erred in concluding that Trapnell had properly substituted into this matter. View "Trapnell & Associates, LLC v. Legacy Resorts, LLC" on Justia Law