Justia Utah Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court dismissing Plaintiff's action seeking to establish his paternity of a child born to Mother, who was married to Husband, holding that section 78B-15-602 of the Utah Uniform Parentage Act (UUPA), Utah Code 78B-15-101 to -902, grants standing to Plaintiff and that subsection 607(1) does not revoke that standing when the child has a presumed father.During Mother's relationship with Plaintiff they conceived a child. Mother and Husband remained married. Plaintiff filed a petition in the district court to challenge Husband's presumed paternity and assert his own parentage. Mother filed a motion to dismiss for failure to state a claim, arguing that subsection 78B-15-607(1) of the UUPA denied Plaintiff standing. The district court dismissed Plaintiff's action. The Supreme Court reversed, holding that section 78B-15-602 grants standing to alleged fathers seeking to adjudicate their paternity, and nothing in subsection 607(1) revokes that standing. View "Castro v. Lemus" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Mother's motion to dismiss Plaintiff's petition to adjudicate his paternity of a child he conceived with Mother while she was married to Father, holding that the Utah Uniform Parentage Act (UUPA) granted standing to Plaintiff to adjudicate his paternity of the child.In her motion to dismiss Mother argued that Plaintiff lacked standing under the UUPA to bring his petition because the child was born within a marriage. The district court denied the motion to dismiss on the basis that to deny Plaintiff standing would violate his procedural due process right under the federal constitution. The Supreme Court affirmed, albeit on alternative grounds, holding that the UUPA grants standing to Plaintiff, and this standing is not altered when the child was conceived or born during a marriage with a presumed father. View "Olguin v. Anderton" on Justia Law

The Supreme Court reversed the district court's judgment permitting Husband to rescind his voluntary denial of paternity of a child on the basis of mutual and unilateral mistake of fact and later granting Husband's petition declaring him to be the child's legal father, which ultimately resulted in the dismissal of Plaintiff's paternity petition, holding that the district court erred in allowing rescission of the denial.During her marriage to Husband, Mother had a sexual relationship with Plaintiff and became pregnant. Before the child's birth, Plaintiff filed a paternity petition in the district court. After the child's birth, genetic testing established that the child was Plaintiff's biological daughter. Husband signed a voluntary denial of paternity renouncing his paternity of the child. Mother moved to dismiss Plaintiff's petition, arguing that he lacked standing under the Utah Uniform Parentage Act to challenge Husband's presumed paternity. Simultaneously, Husband petitioned the district court to declare him to be the child's legal father. The district court allowed rescission of the denial and granted Husband's petition for declaratory judgment. The Supreme Court reversed, holding that where the mistake was not a mistake of fact but, rather, a mistake regarding the legal consequences of signing the declaration and denial, Husband should not have been permitted to rescind the denial. View "Mackley v. Openshaw" on Justia Law

The Supreme Court dismissed as moot this petition addressing whether a law firm that deposited funds from a client into its trust account was a "transferee" under the Uniform Fraudulent Transfer Act (UFTA), Utah Code 25-6-1 to -14, holding that Petitioners had no remedy under the UFTA because they were no longer creditors.The district court granted partial summary judgment for Respondents, the law firm and a lawyer, concluding that they were immune from liability on the fraudulent transfer claims because they were not transferees under the UFTA. While the case was pending before the court of appeals, Petitioners allowed the judgment that formed the basis of their fraudulent-transfer claim to expire. The court of appeals affirmed the district court's grant of summary judgment. On appeal, Respondents argued that even if Petitioners were to prevail on the transferee issue, it would not affect their rights because the fraudulent transfer claims became moot when the judgment expired. The Supreme Court agreed and vacated the court of appeals' decision, holding that the case became moot before the court of appeals' opinion issued. View "Timothy v. Pia, Anderson, Dorius, Reynard & Moss, LLC" on Justia Law

In this interlocutory appeal concerning whether the Brigham Young University (BYU) Police Department is a "governmental entity" subject to the Government Records Access and Management Act (GRAMA), Utah Code 63G-2-101 to -901, the Supreme Court concluded that it would better serve the administration and interests of justice to remand the case back to the district court.The Salt Lake Tribune sent a GRAMA request to BYU's Police Department seeking certain documents. The University Police provided some, but not all, of the documents. The Tribune appealed to the Utah State Records Committee. The Committee denied the appeal, concluding that the University Police was not a "governmental entity" within the meaning of GRAMA and that it lacked jurisdiction. On judicial review, the district court concluded that the University Police is a governmental entity. The court of appeals certified the interlocutory appeal to the Supreme Court. Thereafter, the legislature amended GRAMA to explicitly define the police departments of private universities as governmental entities subject to GRAMA. The Tribune subsequently made a new GRAMA request for the contested records under the amended statute. The Supreme Court declined to decide the issue because answering the question presented will not have any presidential value for future cases or materially affect the final decision in this case. View "Piper v. State Records Committee" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claim for failure to timely file a notice of claim, holding that Plaintiff, a Utah resident injured in Utah by an Arizona municipal employee, may not file a claim against the employee and the municipality after the time to do so has expired under Arizona law but not under Utah law.Plaintiff was involved in a motor vehicle accident in Utah with a driver who was acting in the course and scope of her employment with the City of Flagstaff, Arizona. When Plaintiff filed suit, the City and the driver moved to dismiss arguing that the district court lacked subject matter jurisdiction because Plaintiff did not file her notice of claim within six months as required by Arizona's governmental immunity statute, Ariz. Rev. Stat. 12-821.01. The district court applied the statute as a matter of comity. The Supreme Court affirmed, holding (1) comity was rightfully extended, and the district court correctly applied the statute; and (2) Plaintiff failed to comply with the statute's notice of claim requirement, and therefore, the action was untimely and required dismissal. View "Galindo v. Flagstaff" on Justia Law

In an earlier order explained in this opinion the Supreme Court denied Motorola Solution, Inc.'s Rule 17 motion for stay pending review in this matter involving Utah Communications Authority's (UCA) efforts to hire a private contractor to implement a new statewide emergency public radio system, holding that UCA's motion for a stay was moot.Motorola requested the stay to stop UCA from entering into a contract with Harris Corporation until Motorola's appeal protesting UCA's decision to award that contract for the purpose of implementing the emergency radio system had been resolved. In response, UCA and Harris argued that the motion for a stay was moot because UCAs executive director had already entered into a contract with Harris. Motorola countered that a contract could not be formed until the UCA board had approved it. The Supreme Court denied the motion requesting a stay as moot, holding that the UCA executive director had authority to enter into contracts on UCA's behalf. View "Motorola Solutions, Inc. v. Utah Communications Authority" on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that there was sufficient evidence to sustain the charged aggravator for Defendant's aggravated murder conviction and that the district properly denied Defendant's motion for a new trial, holding that there was no error in the proceedings below.On appeal, Defendant argued that there was insufficient to sustain the determination that he placed another person at "great risk of death" when he killed his victim and that the district court abused its discretion in denying his motion for a new trial. The court of appeals affirmed. The Supreme Court affirmed, holding (1) in determining whether a murder was committed under circumstances in which the defendant caused a "great risk of death" to another person Utah Code 76-5-202(1)(c) is satisfied if the great risk of death was created with a "brief span of time" of the act causing the murder and the acts together "formed a concatenating series of events"; (2) there was a reasonable basis for the jury to conclude that Defendant caused a great risk of death to another in the circumstances of the murder in this case; and (3) the district court did not err in denying Defendant's motion for a new trial. View "State v. Sosa-Hurtado" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court dismissing Plaintiff's claims that Defendant, his employer, fired him in violation of the implied covenant of good faith and fair dealing in his compensation agreement with Defendant, holding that the court of appeals' application of the covenant was improper.In his complaint, Plaintiff claimed that Defendant fired him in an effort to avoid payment of commissions and that, even though he was an at-will employee, his termination violated the implied covenant of good faith and fair dealing. In dismissing the claims, the district court concluded that the covenant could did not apply in this context. The court of appeals reversed, concluding that the covenant can be invoked to prevent employers form using at-will termination to avoid obligations under the compensation agreement. The Supreme Court reversed, holding (1) the covenant of good faith and fair dealing may not be applied to contradict express contractual terms; and (2) the court of appeals' application was inconsistent with the express terms of the compensation agreement and with the parties' course of dealings. View "Vander Veur v. Groove Entertainment Technologies" on Justia Law

In this divorce case, the Supreme Court affirmed the district court's determination that Wife was entitled to alimony but reducing her alimony award in duration and amount because of her extramarital sexual affairs, holding that none of Wife's alleged errors in appeal were an abuse of discretion or plainly incorrect.Specifically, the Court held that the district court (1) properly determined that Wife's infidelities substantially contributed to the end of the marriage; (2) did not abuse its discretion in setting the specific terms of the alimony award; (3) did not err in imputing income to Wife at $1,300 per month; (4) did not err in failing to consider the tax burden of the alimony award; and (5) properly denying Wife's request for attorney fees. View "Gardner v. Gardner" on Justia Law