Justia Utah Supreme Court Opinion Summaries

The Supreme Court reversed in part and vacated in part the judgment of the district court denying Plaintiff's request for a civil stalking injunction against Defendant, holding that the district court erred.Plaintiff ran a residential treatment program for young woman. Defendant, her neighbor, objected to the program's presence in his neighborhood and flipped off and swore at Plaintiff and the program attendees and placed provocative signs in his yard. Plaintiff sought a civil talking injunction, which the district court denied. The Supreme Court reversed in part and vacated in part, holding (1) the district court misinterpreted the stalking statute; (2) the district court failed to assess the impact of Defendant's conduct on a reasonable person in Plaintiff's circumstances; (3) the district court applied an incorrect analysis in deciding that the First Amendment protected Defendant's conduct; and (4) because the reversal of the first three issues may affect the basis for the district court's attorney-fees decision, that decision is vacated, and the matter is remanded for a new determination. View "Ragsdale v. Fishler" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing on summary disposition the denial of Appellant's appeal from the denial of unemployment benefits, holding that following the plain language of Utah Code 35A-4-403 in requiring a claimant who has obtained a work-search deferral to be nonetheless able and available to accept full-time employment does not produce an absurd result.Appellant sought unemployment benefits after he was temporarily laid off from his job. The Department of Workforce Services denied benefits because Appellant had indicated on his application that he was unavailable to accept full-time work because he would be returning to his former employer. The Department deferred the requirement that Appellant actively seek employment while receiving benefits but still required him to be able and available to accept full-time work under section 35A-4-403. The ALJ and the workforce appeals board denied Appellant's appeal. The court of appeals reversed, concluding that interpreting the statute to require a claimant who had obtained a work-search deferral to nonetheless be able and available to accept full-time employment worked an absurd result. The Supreme Court reversed, holding that the Department properly denied Appellant's claim for unemployment. View "Arnold v. Department of Workforce Services" on Justia Law

The Supreme Court answered a certified question posed by the United States Court of Appeals for the Tenth Circuit regarding the reach of the Utah Health Care Malpractice Act (Act), Utah Code 78B-3-401 through 426, by concluding that the Act applied in this case involving an injury sustained while climbing a rock formation during a "wilderness therapy" excursion.Jacob Scott sued Wingate Wilderness Therapy, LLC seeking relief for injuries he sustained as a minor while rock climbing during a wilderness therapy hiking excursion. The federal district court granted Wingate's motion to dismiss, concluding that the Act applied to Scott's claims and that Scott (1) failed to file his action within the two-year statute of limitations, and (2) failed to comply with the Act's procedural requirements. Scott appealed, arguing that the district court erred in finding that his injuries arose out of the health care provided by Wingate. The circuit court certified a question to the Utah Supreme Court, which answered by holding that, under the circumstances of this case, the Act applied to Scott's claims. View "Scott v. Wingate Wilderness Therapy, LLC" on Justia Law

In this case in which in which a sales representative of Alarm Protection Technology (APT) sought to challenge a set of steps taken by APT to insulate itself from claims for unpaid compensation, the Supreme Court held that the district court did not err in denying a motion filed by Plaintiff.Plaintiff, a former sales representative for APT, filed an action alleging that APT and related parties owed him $348,434 in unpaid commissions. This appeal concerned steps taken by APT to insulate itself, including its payment of an advance in exchange for the execution of a confession of judgment, the entry of a judgment by confession, the issuance of a writ of execution against Plaintiff's claims for unpaid commissions, APT's subsequent purchase of those claims, and APT's substitution as plaintiff on the claims against itself. At issue were the district court's denial of Plaintiff's motion for return of excess proceeds and unused property from APT's purchase of his claims. The Supreme Court affirmed, holding that APT was not required to (1) establish the value of Plaintiff's claims before executing on them and purchasing them, (2) presume that the true value of the claims was established in the allegations of Plaintiff's complaint, and (3) return to Plaintiff exceeds proceeds or remaining property on the basis of those allegations. View "Alarm Protection Technology, LLC v. Bradburn" on Justia Law

In this case in which a sales representative of Alarm Protection Technology (APT) sought to challenge a set of steps taken by APT to insulate itself from claims for unpaid compensation, the Supreme Court held that the district court did not err in denying two motions filed by Plaintiff.Plaintiff, a former sales representative for APT, filed an action alleging that APT and related parties owed him $143,000 in treble damages for unpaid commissions. This appeal concerned APT's payment of an advance in exchange for the execution of a confession of judgment, the entry of a judgment by confession, the issuance of a writ of execution against Plaintiff's claims for unpaid commissions, APT's subsequent purchase of those claims, and APT's substitution as plaintiff. Plaintiff specifically appealed the denial of his motion to vacate the judgment by confession and quash the writ of execution of his claims and his motion for return of excess proceeds and unused property from APT's purchase of his claims. The Supreme Court affirmed, holding that APT was not required to (1) establish the value of Plaintiff's claims before executing on them and purchasing them, (2) presume that the true value of the claims was established in the allegations of Plaintiff's complaint, and (3) return to Plaintiff exceeds proceeds or remaining property on the basis of those allegations. View "Alarm Protection v. Crandall" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court in this trust and estate dispute, holding that, under certain circumstances, a party may assert a claim for intentional interference with inheritance.A dozen years after the decedent's death, his children sued David Rudd - the attorney who represented the decedent in various matters - and Ballard Spahr, LLP - the law firm where Rudd was a partner - claiming that Defendants improperly influenced the decedent to amend his will and trust in a way that shifted a portion of the children's expected inheritance to other beneficiaries, engaged in improper and/or misleading conduct, and mishandled estate assets after the decedent's death. On appeal were the district court's grant of (1) Defendants' motion to dismiss the children's claim for intentional interference with inheritance, (2) summary judgment on several tort claims the children wanted to assert on behalf of the decedent's estate, and (3) a motion in limine preventing the children from impeaching Rudd with certain statements. The Supreme Court held that the district court (1) erred in dismissing the intentional interference with inheritance claim; (2) did not err by not assigning the estate's claims to the children; and (3) erred in granting the motion in limine. View "In re Estate of D.A. Osguthorpe, D.V.M." on Justia Law

The Supreme Court affirmed the judgment of the district court denying doTERRA International, LLC's motion for partial summary judgment asserting that Jessica Kruger, who sought, among other things, punitive damages based on doTERRA's failure to warn about the potential dangers of its product, waived the right to seek punitive damages, holding that the trial court correctly denied doTERRA's motion for summary judgment.Kruger, a doTERRA International, LLC distributor, applied a doTERRA product to her skin before visiting a tanning salon and was later diagnosed with second and third-degree chemical burns. doTERRA filed a motion for summary judgment, arguing that Kruger was contractually restricted from seeking punitive damages because she had waived her ability to claim punitive damages in the agreement she signed to become a doTERRA distributor. The Supreme Court affirmed but vacated the district court's reference to doTERRA's contract as one of adhesion, holding that because the waiver in doTERRA's agreement was neither clear nor unambiguous Kruger did not waive her right to sue doTERRA for punitive damages arising out of a personal injury. View "doTERRA v. Kruger" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Shree Ganesh, LLC's contract and tort claims against Weston Logan, Inc., and Matthew Weston, an individual, holding that there remained a genuine dispute as to material facts, precluding summary judgment.Shree Ganesh entered into a contract with Weston Logan to purchase Weston Logan's Best Western Inn. After the sale of the property closed, Shree Ganesh learned about Weston Logan's plans to build a competing hotel across the street. Shree Ganesh subsequently sued Weston Logan for its failure to disclose its plans to develop the competing hotel. The district court granted summary judgment in favor of Weston Logan on all claims. The Supreme Court reversed, holding (1) the purchase agreement was ambiguous as to Weston Logan's disclosure obligations; and (2) there remained a genuine dispute as to material facts relevant to Shree Ganesh's tort claims. View "Shree Ganesh, LLC v. Weston Logan, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that the divorce decree at issue included provisions that, taken as a whole, could be interpreted to suggest that the parties contemplated that alimony would continue upon remarriage, holding that the presumption that alimony terminates upon remarriage was not rebutted in this case.Melvin and Janette McQuarrie divorced in 2008. The district court entered a divorce decree detailing the terms of their mediated stipulation for divorce, under which Melvin was required to pay alimony to Janette. The alimony provisions of the decree did not explicitly address the effect of Janette's remarriage. After Janette remarried, Melvin filed a petition to modify the parties decree, asserting that the remarriage justified a termination of the alimony obligation. The district court denied the motion, holding that the decree language specifically provided that the alimony/child support payments would continue beyond remarriage. The court of appeals affirmed. The Supreme Court reversed, holding that because there was no specific, express provision in the decree that alimony would continue upon remarriage, Melvin's alimony obligation terminated by operation of law. View "McQuarrie v. McQuarrie" on Justia Law

The Supreme Court affirmed the judgment of the juvenile court terminating Mother and Father's parental rights based on years of dysfunctionality, substance abuse, and criminal conduct, holding that the juvenile court did not err.Specifically, the Supreme Court held (1) the juvenile court did not err in declining to apply the "beyond a reasonable doubt" standard of proof, and this Court declines to adopt that standard now; (2) the juvenile court did not err by concluding that termination was strictly necessary and in the children's best interests; and (3) Parents did not carry their burden to brief the issue of whether the court erred in considering a provision from the Human Services Code in its analysis. View "In re G.D." on Justia Law