Justia Utah Supreme Court Opinion Summaries

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

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