Justia Utah Supreme Court Opinion Summaries

The Supreme Court denied the petition for extraordinary writ sought by advocates for a statewide ballot initiative called the Direct Primary Initiative, holding that Petitioners' statutory claims and all but one of the constitutional claims failed on the merit and that Petitioners failed to carry their burden of identifying an undisputed basis for the relief requested.Petitioners - Count My Vote, Inc., Michael O. Leavitt, and Richard McKeown - were advocates for a proposed initiative that would establish a direct primary election path for placement on the general election ballot for persons seeking a political party's nomination for certain elected offices. The lieutenant governor refused to certify the initiative for the November 2018 ballot, finding that Petitioners failed to satisfy the requirements of Utah Code 20A-7-201(2)(a). Petitioners then brought this petition for extraordinary writ on statutory and constitutional grounds. The Supreme Court denied the petition, holding (1) the majority of Petitioners' statutory and constitutional claims failed on the merits; (2) one of the constitutional claims implicates an underlying dispute of material fact on the nature and extent of any burden on the right to pursue an initiative under Utah Const. art. VI, 1; and (3) Petitioners failed to carry their burden of establishing an undisputed basis for the requested relief. View "Count My Vote, Inc. v. Cox" on Justia Law

In this breach of contract action the Supreme Court affirmed the decision of the court of appeals reversing two of the district court's pretrial evidentiary rulings, holding that the court of appeals did not err in holding that the district court incorrectly excluded expert testimony and other evidence proposed by Plaintiff.Plaintiff, Northgate Village Development, LC, brought this action against the City of Orem seeking to recover the cost of cleaning up property Northgate had purchased from the City. The district court granted summary judgment for the City. The court of appeals reversed. On remand, the City made pretrial motions to exclude some of Northgate's proposed evidence. The district court granted the motion as to Northgate's proposed evidence and excluded Northgate's experts as a discovery sanction. Northgate filed an interlocutory appeal. The court of appeals reversed both evidentiary orders. The Supreme Court affirmed, holding (1) the district court erred in excluding Northgate's proposed expert testimony as a discovery sanction because it applied the wrong version of Utah R. Civ. P. 26; and (2) the district court abused its discretion in excluding the challenged evidence as irrelevant under Utah R. Evid. 401 and as prejudicial under Utah. R. Evid. 403. View "Northgate Village Development, LC v. City of Orem" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming Defendant's conviction of failure to signal for two seconds and failure to obey traffic control devices, holding that the Utah Constitution does not guarantee Defendant a jury trial for his traffic violations.At the time Defendant was charged, the Utah Code classified the offenses as class C misdemeanors. At the arraignment hearing the City amended both charges to infractions, thereby depriving Defendant of a jury trial. Defendant moved to dismiss the information charging him with infractions, arguing that the Utah Constitution guarantees a right to a jury trial in all criminal prosecutions, including those for infractions. The justice court denied Defendant's motion to dismiss and request for a jury trial and convicted Defendant. On appeal, the district court denied Defendant's motion for a jury trial and convicted him of both charges. The Supreme Court affirmed, holding that minor offenses do not trigger the right to a jury trial under article I section 12 of the Utah Constitution. View "South Salt Lake City v. Maese" on Justia Law

The Supreme Court reversed the judgment of the district court issuing an injunction enjoining the implementation of Senate Bill 78 (SB 78) on the grounds that it violates article X, section 8 of the Utah Constitution, holding that State Board of Education members are not employed in the state's education systems and are therefore not covered by article X, section 8.In 2016, the legislature passed SB 78, which makes the office of State Board of Education a partisan office and requires Board members to be elected through the general partisan election process. The district court concluded that Board members hold "employment" in a legal sense in the State's education system and therefore fell within the purview of article X, section 8. Thus, the court concluded, SB 78 was unconstitutional. The Supreme Court reversed the district court and reinstated SB 78, holding that because the Utah Constitution omits Board members from being in a condition of employment in the state's education systems, SB 78 does not violate the Utah Constitution. View "Richards v. Cox" on Justia Law

The Supreme Court accepted certified questions of law from the federal court related to a case involving artificial hip implants, answering to what extent implanted medical devices should be immune from strict liability design defect claims under Utah law because they are "unavoidably unsafe," meaning they are "incapable of being made safe for their intended and ordinary use" but their marketing and use is justified because of the benefit they provide.Specifically, the Court answered (1) while some implanted medical devices are unavoidably unsafe, under current federal regulations, this question should be treated as an affirmative defense and determined by the fact-finder on a case-by-case basis with regard to devices that enter the market through the 510(k) process; and (2) for devices that go through a more rigorous premarket approval process, the Court does not opine on whether such devices might be unavoidably unsafe as a matter of law because they are already exempt from design defect claims under the United States Supreme Court's decision in Riegel v. Medtronic, Inc. 552 U.S. 312 (2008). View "Burningham v. Wright Medical Technology, Inc." on Justia Law

The Supreme Court affirmed the award of benefits entered by the Utah Labor Commission in favor of Jessica Wilson, holding that the Commission did not err in concluding that Wilson's injuries arose out of, and in the course of, her employment with her employer, Intercontinental Hotels Group (IHG).Wilson sustained injuries after tripping and falling in a parking lot while walking into work. Wilson requested benefits from IHG. IHG denied Wilson's claim, concluding that, under the going-and-coming rule, Wilson's accident did not arise out of and in the course of her employment. An ALJ with the Commission reviewed Wilson's claim and concluded that Wilson was entitled to benefits under the premises rule. The Commission affirmed, concluding that the communal parking area where the accident occurred was proof IHG's premises for purposes of determining compensability. The Supreme Court affirmed, holding that the Commission properly determined that Wilson's accident occurred on IHG's premises and that, under case law, this constituted an accident in the course of her employment. View "Intercontinental Hotels Group v. Utah Labor Commission" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions for aggravated kidnapping, aggravated robbery, and obstruction of justice, holding that the court of appeals properly concluded that Defendant's free will was not overborne in confessing and making other incriminating statements to the police and properly concluded that a jury instruction given at trial was faulty but did not result in prejudice to Defendant.On appeal, Defendant argued that the court of appeals erred in (1) affirming the trial court's determination that his statements were admissible at trial as impeachment evidence, despite a violation of his Miranda rights, which barred the statements from being used in the Sate's case-in-chief; and (2) erred in affirming his conviction for aggravated robbery despite a jury instruction that incorrectly recited the requisite mental state for the offense. The Supreme Court affirmed, holding (1) the court of appeals correctly affirmed that Defendant's statements to police were voluntary and that his confession and incriminating statements could be used for impeachment purposes in the event that Defendant chose to testify; and (2) the faulty jury instruction did not affect the outcome or the verdict. View "State v. Apodaca" on Justia Law

In answer to three questions certified to it by the federal district court the Supreme Court answered, among other things, that a Utah state district court does not have appellate jurisdiction to review the Utah County Board of Commissioners' decision upholding a fine levied under Utah Code 20A-11-1205.Steven Downs, the Public Information Officer for the City of Orem, was fined for violating the Political Activities of Public Entities Act, specifically, section 20A-11-1205(1)(b), which stated that "a person may not send an email using the email of a public entity...to advocate for or against a ballot proposition." The Board of Commissioners voted to uphold the fine. Downs filed a petition in the federal district court challenging the ruling on several grounds. The federal court reserved ruling on a number of motions until receiving guidance on the three questions certified to the Supreme Court. The Court answered (1) section 20A-11-1205 does not convey appellate jurisdiction on state district courts; (2) the term "ballot proposition" as used in section 20A-11-1205(1) includes the entire referendum process; and (3) a "ballot proposition" as used in section 21A-11-1205(1) includes the entirety of the referendum process even if the challenged local government action is later found to be administrative in nature and therefore not subject to a referendum. View "Downs v. Thompson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing Appellant's motion for declaratory judgment, holding that Utah Code 77-41-105 requires individuals to register as a sex offender in Utah even though their conviction in another jurisdiction has been set aside.Appellant pled guilty in Idaho to a sex offense that required him to register as a sex offender. The entry of judgment was withheld, and after Defendant completed his probation, the court set aside Defendant's plea. When Defendant moved to Utah he filed a lawsuit seeking a declaratory judgment that he was not required to register in Utah because he was never actually convicted in Idaho. The district court dismissed the suit. The court of appeals affirmed, holding that section 77-41-105(3)(a) required Defendant to register regardless of whether he was convicted because he met the definition of an "offender." The Supreme Court affirmed, holding (1) Appellant was required to register as a sex offender in Utah based on his status as an offender; and (2) Appellant was required to register in Utah because he was convicted in Idaho. View "Holste v. State" on Justia Law

The Supreme Court reversed the judgment of the district court ruling against Appellant in this declaratory judgment action and holding that the Office of Recovery Services (ORS) was entitled to recover from the portion of Appellant's settlement award representing all medical expenses, both past and future, holding that ORS may recover from only that portion of an award representing past medical expenses.Appellant brought malpractice and negligence claims against a hospital, alleging that the hospital's failure to diagnose his stroke caused severe injuries. At the time of his injuries, Appellant received Medicaid through the State, and Medicaid paid for Appellant's treatment. At issue here was what portion of Appellant's settlement award the ORS was permitted to collect. The district court held that ORS was entitled to recover from the portion of Appellant's settlement award representing all medical expenses, both past and future. The Supreme Court disagreed and remanded the case, holding that ORS may place a lien on and recover from only that portion of Appellant's settlement representing past medical expenses. View "Latham v. Office of Recovery Services" on Justia Law