Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court against Plaintiff on his medical malpractice claims against LDS Hospital, holding that the trial court did not err in instructing the jury.While undergoing abdominal surgery Plaintiff suffered a cardiac arrest, and his heart did not beat for more than fifteen minutes. Plaintiff suffered brain damage as a result. At trial, LDS Hospital moved for summary judgment on the grounds that the action was time barred. After a bifurcated trial, the jury found that Plaintiff discovered or should have discovered his legal injury more than two years before he commenced the action, and therefore, the action was barred by the statute of limitations. On appeal, Defendant argued that the trial court incorrectly instructed the jury on "discovery of legal injury." The Supreme Court disagreed, holding that, when viewed as a whole, the trial court's instructions to the jury correctly stated the law relevant to discovery of a legal injury. View "Jensen v. IHC Health Services, Inc." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the district court in favor of Plaintiff in this personal injury action, holding that the district court abused its discretion in allowing Plaintiff's expert witness to offer undisclosed causation testimony, and the error was harmful.Plaintiff, who was injured while working on a highway construction site, sued the general contractor for failing to take necessary safety measures to protect workers from highway traffic. The jury found that the general contractor was partially liable for Plaintiff's injury. On appeal, the general contractor argued that the district court erred when it allowed Plaintiff's expert witness to offer an undisclosed opinion on causation. The court of appeals agreed, determining that the error was harmful enough to warrant reversal and a new trial. The Supreme Court affirmed, holding that the testimony was erroneously admitted and that the error was not harmless. View "Arreguin-Leon v. Hadco Construction, LLC" on Justia Law

The Supreme Court reversed the portion of the court of appeals' opinion reversing the district court's valuation decision regarding the just compensation as to a certain parcel of land, holding that Appellant did not provide a plausible basis for reversal of the district court.The Utah Department of Transportation (UDOT) condemned property owned by Coalt, Inc. (Parcel 84) in connection with the Legacy Parkway Project. UDOT later entered into a settlement agreement with public interest litigants agreeing to acquire additional mitigation property in connection with the Legacy Nature Preserve. This property included Parcel 84. Coalt argued that UDOT did not take Parcel 84 for the Legacy Parkway and therefore did not have the authority to condemn the property. In the alternative, Coalt argued that Coalt's compensation for the taking should include any increased market value caused by Parcel 84's proximity to the Legacy Parkway. The court of appeals concluded that UDOT had the authority to condemn Coalt's land but that just compensation should include any enhanced value caused by the Legacy Parkway. The Supreme Court reversed in part, holding (1) UDOT had authority to condemn Parcel 84 as mitigation for the Legacy Parkway Project; and (2) Coalt did not provide a plausible basis for reversal of the district court's valuation decision. View "Utah Department of Transportation v. Coalt, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court denying a civil stalking injunction sought by Kristi Ragsdale against George Fishler, holding that the district court erred.Ragsdale ran Eva Carlton Academy (ECA), a residential treatment program for young women, out of her home in a suburb. Fishler, Ragsdale's neighbor, expressed his objection to ECA's presence in the neighborhood by flipping off and swearing at Ragsdale and others entering or exiting ECA and by placing provocative signs in his yard. The district court denied Ragsdale's request for an injunction. The Supreme Court reversed on each issue raised by Ragsdale and vacated the district court's ruling on Fishler's fee request, holding that the district court erred by (1) concluding that Fishler's conduct was directed only at ECA; (2) failing to determine whether Fishler's conduct would cause a reasonable person in Ragsdale's circumstances to suffer fear or emotional distress; and (3) denying Ragsdale's injunction on the ground that the First Amendment protects Fishler's conduct. Because the Court's reversal of these issues may affect the basis for the district court's denial of Fishler's attorney-fees request, the Court vacated that decision and remanded for a new determination. View "Ragsdale v. Fishler" on Justia Law

The Supreme Court affirmed the decision of the Labor Commission awarding Appellant permanent partial disability under the Workers' Compensation Act (WCA), Utah Code 34A-2-101 to -1005, holding that the Commission's process for determining permanent partial disability benefits is constitutional and that the administrative law judge (ALJ) was not permitted to increase the amount of the award based on Appellant's subjective pain.Based on Commission guidelines, the ALJ based the amount of Appellant's award on a report provided by an assigned medical panel. Appellant argued on appeal that the process for determining permanent partial disability benefits was unconstitutional and that the ALJ erred in failing to augment the medical panel's impairment rating by three percent, resulting in an increased compensation award. The Supreme Court disagreed, holding (1) the adjudicative authority of ALJs has not been unconstitutionally delegated to medical panels; and (2) the Commission expressly precludes ALJs from augmenting an impairment rating based on a claimant's subjective pain. View "Ramos v. Cobblestone Centre" on Justia Law

The Supreme Court affirmed in part and reversed in part the district court's judgment granting Bradley Scott's motion to terminate alimony, holding that the court correctly terminated alimony under the couple's divorce decree, which provided that Jillian Scott's alimony would terminate "upon" her "cohabitation."After Jillian and Bradley divorced, Jillian began dating James Okland. When Jillian and Okland broke up, Bradley filed a petition to terminate his alimony payments on the grounds that Jillian had cohabited with Okland. The district court terminated alimony pursuant to Utah Code 30-3-5(10). The court of appeals affirmed. The Supreme Court reversed, holding that section 30-3-5(10) requires the paying spouse to establish that the former spouse is cohabiting at the time the paying spouse moves to terminate alimony. On remand, Bradley moved to terminate alimony under the divorce decree. The district court granted Bradley's motion and denied Jillian's motion for an award of costs in the Scott I appeal. The Supreme Court held (1) the district court did not violate the mandate rule in addressing Bradley's motion under the divorce decree; (2) the court correctly determined that Jillian cohabited with Oakland under the terms of the decree; and (3) Jillian was entitled to an award of her costs on appeal in Scott I. View "Scott v. Scott" on Justia Law

In this adoption proceeding involving a child, B.B., whose biological parents were members of the Cheyenne River Sioux Tribe (the Tribe), the Supreme Court reversed the district court's judgment transferring this case to the tribal court under 25 U.S.C. 1911(a) of the Indian Child Welfare Act on the ground that B.B. was "domiciled within the reservation," holding that the Tribe did not have exclusive jurisdiction over this case.B.B. was born in Utah to Father and Mother, who were unmarried, and placed for adoption in a proceeding filed in the Third District Court. Father and the Tribe moved to transfer the case to the tribal court under section 1911(a), which provides that an "Indian tribe" has exclusive jurisdiction "over any child custody proceeding involving an Indian child who resides or is domiciled within the reservation of such tribe...." The district court granted the motion on the grounds that B.B. was domiciled within the reservation at the time this action was filed. The Supreme Court reversed, holding that the district court had jurisdiction because (1) Mother was domiciled in Utah at the time of B.B.'s birth, and (2) Mother's initiation of formal adoption proceedings did not constitute an abandonment that shifted B.B.'s domicile to that of Father, who was domiciled on the reservation. View "In re Adoption of B.B." on Justia Law

The Supreme Court affirmed the judgment of the district court denying Father's motion to revoke his relinquishment of parental rights, holding that the district court correctly concluded that Father's relinquishment was voluntary, and any failure to notify Father of his statutory right to receive counseling did not invalidate the relinquishment.Father consented to the adoption of his biological daughter and signed a relinquishment of parental rights. Later, Father filed a motion to revoke his relinquishment, alleging that his relinquishment was involuntary. The district court denied the motion. The Supreme Court affirmed, holding (1) Father failed to identify an evidentiary basis for his allegation that his relinquishment was involuntary; (2) Father did not have a due process right to have his relinquishment invalidated by the adoptive parents' failure to notify him of his statutory right receive counseling; and (3) Father lacked standing to assert an equal protection challenge to the relinquishment requirements that apply to biological fathers. View "S.A.S. v. K.H.B." on Justia Law

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