Justia Utah Supreme Court Opinion Summaries

The Supreme Court dismissed this case in which Petitioner filed a petition for extraordinary relief challenging the decision of the Utah Board of Pardons and Parole rescinding Petitioner's parole date based on unadjudicated allegations that Petitioner had abused a child and supplied a minor with drugs and alcohol, holding that the case was moot.In her petition for extraordinary relief, Petitioner argued that the Board's decision to rescind her parole date violated her state and constitutional rights and asked that her original parole date be reinstated. The district court granted summary judgment for the State. After Petitioner filed this appeal, the Board paroled her. The Supreme Court dismissed the case as moot, holding that Petitioner's case was moot and that Petitioner did not demonstrate that the public interest exception applied. View "Widdison v. Utah Board of Pardons & Parole" on Justia Law

In this dispute over a Nibley City ordinance approving a development project on property owned by Return Development LLC the Supreme Court reversed the judgment of the district court finding that a referendum petition opposing the ordinance was sufficient as a matter of law under the Election Code, as modified by Executive Order 2020-14, holding that the district court erred.Several citizens of the City collected signatures in support of a referendum petition, some of which were collected through a process initiated by a document sent to voters by mail, which directed them to an online version of the referendum packet. The Nibley City Recorder rejected the petition on the ground that the signatures collected in response to the mailer were not valid. The district court overruled that decision. The Supreme Court reversed, holding (1) the signatures procured through the mailed document were not valid because they did not meet the requirements of Utah Code 20A-7-604(4); and (2) this statutory requirement was not altered when the governor suspended enforcement of some Election Code provisions in Executive Order 2020-14, which was entered in response to the COVID-19 pandemic. View "Smith v. Return Development LLC" on Justia Law

The Supreme Court vacated Defendant's conviction of child abuse and remanded the case to the district court to enter findings about whether the punishment that Defendant gave his son was "reasonable discipline."Defendant spanked his son with enough force to leave bruises in the shape of a handprint on the child's bottom that were visible two days later. Defendant was charged with child abuse under Utah Code 76-5-109(3)(c). The court of appeals affirmed. The Supreme Court vacated the conviction and remanded the case for further proceedings, holding that the court of appeals erred in determining that it was "clear from the record" that the district court correctly applied and analyzed the statute's "reasonable discipline" provision. View "Bountiful City v. Baize" on Justia Law

The Supreme Court reversed the judgment of the district court denying the State's motion in limine to admit unsworn statements witnesses made to officers shortly after the shooting in which they defined Defendant as the person who fired the shots, holding that the district court erred.After the two witnesses identified Defendant as the gunman they later recanted. The State sought to call the witnesses to testify and to impeach them with their first version of their story. The district court entered an order preventing the State from calling the witnesses, concluding that it would be improper to allow the prior inconsistent statements to come before the jury. The Supreme Court reversed, holding that the district court misinterpreted the Utah Rules of Evidence and that nothing in the rules prohibits the State from calling witnesses to give potentially unhelpful testimony if the State plans to impeach the witness with her helpful prior inconsistent statements. View "State v. Biel" on Justia Law

The Supreme Court reversed the district court's dismissal of this complaint brought by the Southern Utah Wilderness Alliance (SUWA) alleging that the San Juan County Commission violated SUWA's rights under Utah's Open and Public Meetings Act, Utah Code 52-4-101 to 52-4-305, holding that SUWA's complaint was sufficient to survive dismissal.The district court dismissed the complaint on the grounds that SUWA failed to allege that the participants in the disputed meetings had discussed a matter over which the Commission had jurisdiction or advisory power. The Supreme Court reversed, holding (1) SUWA had standing to bring a challenge under the Act; and (2) the district court erred in dismissing SUWA's claims because the pleadings in SUWA's complaint were sufficient even if this Court were to adopt a proposed interpretation of the Act proffered by the Commission. View "Southern Utah Wilderness v. San Juan County Commission" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing this complaint brought by the Southern Utah Wilderness Alliance (SUWA) alleging that the Kane and Garfield County Commissions violated Utah's Open and Public Meetings Act (the Act), Utah Code 52-4-101 to 52-4-305, holding that the district court erred.The dispute leading to this litigation was whether the Commissions violated the Act when they failed to provide public notice or allow attendance at certain Commission members had with the United States Secretary of the Interior. The district court dismissed SUWA's complaint for lack of standing and concluded that the Act did not apply to the meetings at issue. The Supreme Court reversed, holding (1) SUWA had standing to bring these claims; and (2) the court erred in concluding that the Act did not apply because, even under the district court's interpretation of the Act, the allegations in SUWA's complaint were sufficient to survive a motion to dismiss. View "Southern Utah Wilderness Alliance v. Kane County Commission" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing this wrongful death suit against Salt Lake City on the grounds that the action was barred by Utah's Limitations on Landowner Liability Act's prohibition on claims for personal injury caused by the inherent risks of participating in an activity with a recreational purpose, holding that Plaintiffs sufficiently alleged that the death in this case was not caused by a risk inherent in a recreational activity.Liudmila Feldman drowned in a creek at a City park when walking her dogs. Feldman tried to get the dogs out of the creek within the park but was caught in a dangerous current and drowned. Plaintiffs sued the City for wrongful death and other causes of action, asserting that the dangerous current at the creek resulted from manmade developments. The district court granted the City's motion to dismiss, concluding that Utah Code 57-14-401 barred Plaintiffs' claims. The Supreme Court reversed, holding (1) the district court correctly held that application of section 401 does not violate the wrongful death clause of the Utah Constitution; but (2) Plaintiffs sufficiently alleged that Feldman's death was not caused by an inherent risk in her recreational activity of walking in the park with her dogs. View "Feldman v. Salt Lake City Corp." on Justia Law

The Supreme Court reversed the judgment of the district court denying Alexie Kamoe's petition for extraordinary relief, holding that an appeal from a negotiated plea in justice court under Utah Code 78A-7-118(3) does not vacate that court's judgment.Kamoe was charged in justice court with three separate criminal counts. Pursuant to a plea agreement, Kamoe pled guilty to a single count of impaired driving. Kamoe appealed to district court but withdrew the appeal after the denial of her motion to suppress blood-test evidence. Kamoe then returned to justice court seeking to have her original conviction, sentence, and commitment reinstated. The prosecutor, who wanted Kamoe to face trial on the initial three counts, objected. The justice court denied Kamoe's request for reinstatement. Kamoe then filed a petition for extraordinary relief under Utah R. Civ. P. 65B(d)(2). The district court denied the petition. The Supreme Court reversed and remanded the case to the justice court with instructions to reinstate Kamoe's original judgment, holding that a criminal defendant's appeal of a guilty plea made in justice court does not void that court's conviction, sentence and commitment. View "Kamoe v. Honorable Stevan Ridge" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony driving under the influence (DUI) and possession of drugs and drug paraphernalia, holding that the exclusionary rule does not apply where law enforcement relied reasonably on then-existing precedent.In affirming Defendant's conviction, the court of appeals held that the police had the reasonable suspicion necessary to temporarily detain Defendant in his vehicle and ask him to step out of it. The Supreme Court affirmed, holding (1) this Court repudiates the sweeping language of its opinion in State v. James, 13 P.3d 576 (Utah 2019), and holds that the identity of the opener of a car door may affect the reasonableness of any given police encounter; but (2) the evidence here was not subject to exclusion because the police acted objectively reasonably in reliance on the Supreme Court's opinion in James. View "State v. Malloy" on Justia Law

The Supreme Court affirmed on all but one issue the judgment of the court of appeals affirming Defendant's convictions for violation of a protective order, three counts of aggravated sexual assault, kidnapping, burglary, and assault, holding that the district court erred by not instructing the jury on sexual battery as a lesser included offense of the aggravated sexual assault charge based on forcible sexual abuse.Specifically, the Supreme Court held (1) any error in the jury instructions for aggravated sexual assault and the underlying offenses of rape and forcible sexual abuse were not prejudicial; (2) the district court did not err by not instructing the jury on any of the lesser included offenses Defendant requested, except for sexual battery; and (3) at sentencing, the district court did not err in imposing a punishment of fifteen years to life for aggravated sexual assault. View "State v. Norton" on Justia Law