Justia Utah Supreme Court Opinion Summaries

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

The Supreme Court reversed the order of the district court denying the Utah State Tax Commission's motion to dismiss Gail and Margaret Christensens' petition seeking judicial review of an order of an administrative law judge (ALJ) requiring Gail to pay income tax and interest on income he earned while working in the Republic of Angola, holding that the Christensens did not exhaust their administrative remedies prior to seeking judicial review.Gail did not file Utah tax returns for the three years he was working in Angola. The Auditing Division of the Commission ordered Gail to pay his taxes, along with interest and penalties. Gail challenged that decision, and an ALJ ordered him to pay taxes and interest but not a penalty. Gail did not request a formal hearing before the Commission but, instead, sought review of the order, along with his wife, in the district court. The Commission moved to dismiss the petition on the grounds that the district court lacked jurisdiction. The district court denied the motion to dismiss. The Supreme Court reversed, holding that, by failing to request a formal hearing, the Christensens did not exhaust their administrative remedies, as required by the Utah Administrative Procedures Act. View "Christensen v. Utah State Tax Commission" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction for burglary and sexual abuse, holding that any error found or assumed in this case was not prejudicial.On appeal, Defendant argued that the prosecutor's comments about he differences between his initial statement at the scene of the crime and his trial testimony violated his constitutional right to remain silent and that the trial court's admission of two prior acts - a peeping incident and a trespassing incident - was prejudicial error. The Supreme Court affirmed, holding (1) assuming that a constitutional violation occurred during the prosecutor's cross-examination about omissions in Defendant's statement at the scene, the violation was harmless beyond a reasonable doubt and did not prejudice Defendant; (2) any assumed error in the admission of the trespassing incident was harmless; and (3) Defendant failed to preserve his challenge to the admission of the peeping incident. View "State v. Argueta" on Justia Law