Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the district court's dismissal of the Pearl Raty Trust's claim that it is an inhabitant of Salt Lake City and thereby entitled to the City's water under Utah Const. art. XI, 6, holding that the Trust failed to persuade the Court that the Utah voters who ratified the Constitution would have considered it an inhabitant of the City.The Trust sought water for an undeveloped lot it owned in Little Cottonwood Canyon. Although the lot sat in unincorporated Salt Lake County, the lot fell within Salt Lake City's water service area. The court of appeals ruled that the Trust was not an inhabitant of the City because it "merely holds undeveloped property within territory over which the City asserts water rights and extra-territorial jurisdiction." The Supreme Court affirmed, holding that the Trust failed to persuade that the people who ratified the Utah Constitution understood the word "inhabitants" to encompass any person who owned property in a city's approved water service area. View "Salt Lake City Corp. v. Haik" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of aggravated sexual assault and aggravated assault, holding that Defendant was not prejudiced by any alleged error in the jury instruction for rape and that the State had no duty under Brady v. Maryland, 373 U.S. 83 (1963), to conduct a forensic examination of the complainant's cell phone before trial.The court of appeals affirmed Defendant's convictions, holding that (1) the district court had not erroneously instructed the jury on the elements of rape, and (2) the State did not commit a Brady violation. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by his counsel's failure to object to the jury instruction on the elements of rape, and, going forward, this Court endorses the use of Model Utah Jury Instruction 1605 for rape; and (2) the State did not violate Brady when it did not complete a forensic examination of the complainant's cell phone. View "State v. Newton" on Justia Law

In this longstanding dispute between attorney Gregory Jones and his former law firm, Mackey Price Thompson & Ostler, P.C. (MPTO), over the distribution of litigation proceeds the Supreme Court upheld the jury's $647,090 verdict on Jones's quantum meruit/unjust enrichment claims, holding that the district court did not abuse its discretion in admitting the testimony of Jones's expert witness.Jones claimed a right to some of the fees collected by MPTO in personal injury cases arising out of the use of the drug known as Fen-Phen. Jones asserted claims for fraudulent transfer, quantum merit/unjust enrichment, breach of fiduciary duty and sought an award of punitive damages and to impose a constructive trust on the funds held by MPTO. A jury ultimately entered a verdict against MPTO on a quantum meruit/unjust enrichment theory and dismissed or rejected Jones's remaining claims. After a trial, the district court concluded that the judgment extended to Mackey Price, LLC, an entity the court ruled was a successor in interest to MPTO. The Supreme Court reversed the dismissal of Jones's fraudulent transfer and punitive damages claims, the decision that a constructive trust was categorically unavailable, and the default determination that Mackey Price, LLC was a successor in interest to MPTO and otherwise affirmed the district court. View "Jones v. Mackey Price Thompson & Ostler" on Justia Law

The Supreme Court upheld the constitutionality of Utah Code 78A-7-118(4), (8) providing a hearing de novo in the district court on justice court convictions but foreclosing further appeal unless the district court rules on the constitutionality of a statute or ordinance, holding that the statute withstands constitutional scrutiny.Petitioner was convicted of three misdemeanors in justice court. Thereafter, Petitioner invoked his statutory right to appeal his convictions by seeking a trial de novo in the district court. In the district court, Petitioner was acquitted of one misdemeanor and reconnected of the other two. By statute, Petitioner had exhausted his right to an appeal following the district court's decision, but Petitioner nonetheless filed an appeal in the court of appeals. The court of appeals held that it lacked jurisdiction and dismissed the appeal. Petitioner sought certiorari review, arguing that 78A-7-118(8) is unconstitutional as applied to him. The Supreme Court affirmed, holding that while the briefing in this case has highlighted some potential policy concerns with the process for filing an appeal from a justice court decision none of these concerns rises to the level of a constitutional problem. View "Taylorsville City v. Mitchell" on Justia Law

In this medical malpractice action, the Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court excluding Plaintiffs' proximate cause expert's testimony, holding that the district court did not err.Plaintiffs brought suit against the University of Utah Hospital alleging that the Hospital's treatment of their daughter's baclofen withdrawal caused the daughter's permanent injuries. The Hospital filed a motion in limine to exclude the testimony of Plaintiffs' causation expert, arguing that the testimony should be barred under Utah R. Evid. 702 because the expert's opinion was not based upon sufficient facts or data. The district court agreed and excluded the testimony. At issue on appeal was whether the threshold showing that the principles or methods underlying in the expert's testimony were based upon sufficient facts or data where the method - logical deduction - was based upon broad and attenuated facts. The Supreme Court held that the showing was not present in this case, and therefore, the district court properly excluded the expert testimony on proximate cause. View "Taylor v. University of Utah" on Justia Law

The Supreme Court affirmed the judgment of the district court, on summary judgment, ruling that a prescriptive easement had been formed, but held that the court incorrectly instructed the jury regarding the scope of the prescriptive easement and therefore remanded the case for a new trial with the correct jury instruction.On summary judgment, the district court determined that Appellees had established a prescriptive easement across the property of Appellants. After a trial for a determination of the scope of that easement, the jury returned a verdict, and the court entered a final judgment. The Supreme Court held (1) on summary judgment, the district court did not err in ruling that a prescriptive easement had formed; (2) the district court did not abuse its discretion in its decisions regarding the admissibility of the parties' respective expert witnesses; but (3) the district court erred in instructing the jury regarding the scope of the prescriptive easement, necessitating a new trial. View "Harrison v. SPAH Family Ltd." on Justia Law

The Supreme Court reversed the judgment of the district court determining that SRB Investment Company had established a prescriptive easement but prohibiting SRB from using the easement for any reason other than to access the SRB property for the purposes of ranching or farming, holding that the court improperly focused on the purposes for which SRB's land would be used rather than on the purpose for which the relevant portion of the servant estate would be used.SRB sought access to its property through a prescriptive easement crossing land owned by the Spencer family. The district court determined that SRB had acquired a prescriptive easement across the Spencer property and then limited the scope of the easement. The Supreme Court reversed, holding that the district court erred in defining the scope of the easement based on how SRB used its own property during the prescriptive period and instead should have defined the scope of the easement based on how SRB used the Spencer's property during that period. View "SRB Investment Co., Ltd. v. Spencer" on Justia Law

The Supreme Court affirmed the decision of the district court denying the motion for attorney fees filed by Gold's Gym International, Inc. after it prevailed in a suit filed by members of a limited liability company (members) that had licensed Gold's Gym's name to operate a fitness center, holding that the issues properly before the Court did not convince the Court that the district court erred.In denying attorney fees, the district court reasoned that the members, as individuals, were not parties to the license agreement between Gold's Gym and the LLC that contained the fee provision and that the members' claims did not relate to or arise out of that agreement. On appeal, Gold's Gym argued that if someone who is not a party to a contract tries to enforce its terms, it must also assume the risks and obligations that the contract imposes. The Supreme Court affirmed without reaching the merits of the issue, holding (1) issues of preservation and waiver precluded the Court from reaching the heart of Gold's Gym's argument on appeal; and (2) Gold's Gym's remaining arguments were unavailing. View "Chamberlain v. Golds Gym International, Inc." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of attempted murder, holding that the court of appeals did not err in denying Defendant's Utah R. App. P. 23B motion, nor was Defendant prejudiced by his trial counsel's decision not to call an expert who would have testified about the problems inherent in eyewitness identifications.On appeal, Defendant argued that his trial counsel rendered ineffective assistance by failing to call the eyewitness testimony expert, who his prior counsel had previously identified and disclosed. Defendant also filed a Rule 23B motion asking the court to remand so that he could supplement the record with facts concerning the uncalled expert. The court of appeals denied the Rule 23B motion and affirmed Defendant's conviction. The Supreme Court affirmed, holding that the court of appeals (1) did not err by concluding that Defendant failed to present a sufficient basis for remand under Rule 23B; and (2) did not apply an incorrect version of the Washington v. Strickland, 466 U.S. 668 (1984), standard to its conclusion. View "State v. Gallegos" on Justia Law

In these three medical malpractice actions the Supreme Court affirmed in part and reversed in part the district court's denial of Defendants' motions to dismiss and remanded to uphold Plaintiffs' opportunity to develop and present evidence in support of the "fraudulent concealment" exception to the two-year limitations period, holding that Plaintiffs sufficiently alleged fraudulent concealment to avoid dismissal and that the sufficiency of the evidence was a matter for summary judgment or trial.In each case, Defendants moved to dismiss on the ground that Plaintiffs' claims were time-barred under the Utah Health Care Malpractice Act and that the time bar was not tolled by either the foreign object or fraudulent concealment exceptions set forth in the statute in part because Plaintiffs did not allege fraudulent concealment with the particularity required by Utah R. Civ. P. 2(c). The motions to dismiss were denied in large part. The Supreme Court affirmed the decisions denying the motions to dismiss on time-bar grounds and reversed the decision dismissing the negligent credentialing claim, holding (1) Plaintiffs sufficiently alleged fraudulent concealment to avoid dismissal; (2) the foreign object exception did not apply in this case; and (3) the Act did not retroactively bar Plaintiffs' negligent credentialing claims. View "Bright v. Sorensen" on Justia Law