Justia Utah Supreme Court Opinion Summaries

In this case asserting various claims against a number of defendants, the Supreme Court dismissed this appeal, holding that the district court’s order was not a final judgment because the court failed to dispose of Plaintiffs’ civil conspiracy claim against two defendants.In their complaint, Plaintiffs asserted twenty-five causes of action against multiple defendants. The district court granted partial summary judgment and summary judgment in favor of some defendants on several causes of action and granted default judgment against two defendants on some claims. After post-trial proceedings, the district court issued its amended final order of judgment. Both parties appealed. The Supreme Court dismissed the case for lack of appellate jurisdiction, holding that the record indicated that the district court’s final order did not dispose of all claims brought by Plaintiffs against two defendants, and therefore, the final judgment rule was not met. View "Wittingham, LLC v. TNE Limited Partnership" on Justia Law

The Supreme Court reversed the state district court’s dismissal of Appellant’s petition asking the court to force the Utah Highway Patrol and Utah Department of Public Safety (collectively, UHP) to return his money held for forfeiture, holding that the court had in rem jurisdiction over Appellant’s funds under the Forfeiture and Disposition of Property Act (Act).The UHP seized Appellant’s funds in the amount of $500,000 under the Act. The money sat in a UHP bank account for seventy-five days, and no Utah state district court filed forfeiture proceedings. Meanwhile, a federal magistrate issued a seizure warrant for the money on behalf of the DEA. While UHP sent a check for the cash amount, the DEA never cashed the check. Appellant filed a petition in state district court requesting a return of his funds because the prosecuting attorneys failed to take action under Utah Code 24-4-104(1)(a) to avert a law enforcement duty to “return [the] seized property.” The UHP ultimately dismissed the petition, concluding that it lacked in rem jurisdiction of the seized funds based on principles of comity. The Supreme Court reversed and remanded, holding that the district court had in rem jurisdiction over the property because it was the first to properly exercise in rem jurisdiction to the exclusion of any other court. View "Savely v. Utah Highway Patrol" on Justia Law

The Supreme Court dismissed this appeal for lack of appellate jurisdiction, holding that the Utah R. Civ. P. 54(b) certifications were flawed. The Court then clarified the steps parties and district courts must take to ensure proper certification under Rule 54(b) in order to avoid unnecessary remands.Acting pursuant to Rule 54(b), the district court sought to certify as final and appealable several orders related to the disposition of mechanic’s liens. Plaintiff appealed those orders. The Supreme Court dismissed the appeal in its entirety, holding that the 54(b) certification orders at issue were deficient for four reasons outlined in this opinion. View "Copper Hills Custom Homes, LLC v. Countrywide Bank, FSB" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the district court’s denial of Appellant’s motion to amend his counterclaim and to join a party, holding that it lacked appellate jurisdiction because the district court’s order did not offer sufficient findings and conclusions to understand the court’s reasoning and because the district court did not enter findings supporting the conclusion that the certified order was final.The parties presented this case as an appeal from a final order pursuant to Utah R. Civ. P. 54(b), but the district court’s rule 54(b) certification did not make the requisite express determination that there was no just reason for delay. Further, the district court failed to offer the necessary rational under Utah R. Civ. P. 52(a), which functioned as a practical bar to the Supreme Court’s appellate jurisdiction. Therefore, the district court did not enter any final order in this case, and no exception to the final judgment rule existed conferring appellate jurisdiction on the Supreme Court. View "First National Bank of Layton v. Palmer" on Justia Law

The Supreme Court revoked certification in this case certified to it by a bankruptcy court to answer a question of state law because the issues were not adequately briefed and because of the potential impact of the automatic stay on the property settlement at issue in this case.The bankruptcy court certified two questions of Utah law concerning the overlap of family and bankruptcy law. The Court noted that the parties failed to provide the briefing needed to answer the questions here and that the martial property division at issue in this case may have violated the automatic stay that accompanies a bankruptcy petition’s filing. Accordingly, because of the insufficient briefing and the problematic procedural posture, the Supreme Court declined to answer the questions and revoked certification. View "In re Deborah Michelle Kiley" on Justia Law

The Supreme Court dismissed the interlocutory appeal brought by Defendant challenging the district court’s decision to quash a subpoena Defendant sought seeking against his alleged victim to testify at his preliminary hearing, holding that the decision had been mooted and that the Court lacked jurisdiction to address the district court’s decision to bind Defendant over for trial.Defendant appealed the district court’s decision to quash the subpoena but did not appeal the district court’s determination that probable cause existed for him to face trial. Because the decision Defendant appealed had been mooted by the subsequent bindover and the Supreme Court lacked jurisdiction to consider the bindover decision, the Court dismissed this appeal and remanded the case. View "State v. Hernandez" on Justia Law

The Supreme Court affirmed the district court’s finding that Mark Haik lacked standing to challenge a change application that sought to add acreage to accommodate a private water system and the court’s denial of Haik’s motion to amend his petition, holding that the district court did not err or abuse its discretion.Haik, who wanted water for his undeveloped canyon lots, challenged a change application that would add acreage to accommodate a water system that would serve ten homes in Little Cottonwood Canyon. After the State Engineer approved the application, Haik filed petition seeking a trial de novo of the State Engineer’s order. Haik also moved for leave to amend. The district court dismissed Haik’s petition, concluding that it lacked jurisdiction because Haik lacked standing where the change application did not directly impact Haik’s property or his water rights. The court also denied Haik’s motion to amend. The Supreme Court affirmed, holding (1) Haik lacked standing because he was not aggrieved by an order of the State Engineer; and (2) Haik’s motion to amend was properly denied because Haik did not attach a proposed amended petition and any amendment would be futile. View "Haik v. Jones" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of reckless aggravated abuse of a vulnerable adult and interference with an arresting officer, holding that the district court did not err in excluding evidence of the victim’s prior sexual misconduct and correctly instructed the jury.Defendant received a sentence enhancement for his convictions because he qualified as a habitual violent offender. On appeal, Defendant argued that the district court erred in excluding the victim’s prior sexual misconduct evidence and in instructing the jury. The Supreme Court found no error as to these issues. Defendant also argued that Utah’s aggravated abuse of a vulnerable adult statute was unconstitutionally vague and that Utah’s habitual offender statute violated the Utah Constitution’s cruel and unusual punishment clause and the double jeopardy clause. The Supreme Court disagreed, holding that Utah’s aggravated abuse statute is not unconstitutionally vague and that Utah’s habitual violent offender statute is constitutional. View "State v. Tulley" on Justia Law

The Supreme Court vacated the jury’s $2.75 million award for non-economic damages in this legal malpractice and breach of contract case, holding that the case did not qualify as one of the “rare” cases where non-economic damages can be recovered for breach of contract.Plaintiff sued Defendants for legal malpractice, breach of contract, breach of fiduciary duty, and negligent hiring, training, and supervision after Defendants failed to bring Plaintiff’s claim before the statute of limitations ran. The jury found in favor of Plaintiff on each of the claims, awarding her $750,000 in damages for breach of contract and $2.75 million for the emotional distress Plaintiff suffered as the result of the malpractice. The Supreme Court vacated the non-economic damages award, holding that, under either a breach of contract or breach of fiduciary duty theory, the district court erred in upholding the award for emotional distress damages. The Court also vacated the attorney fees award and held that the district court correctly denied Plaintiff’s litigation expenses. View "Gregory & Swapp, PLLC v. Kranendonk" on Justia Law

In holding that the successor judge in this case had authority to dismiss Plaintiff’s claims for breach of contract and consequential damages and committed no reversible error by doing so, the Supreme Court repudiated any language in its precedent that suggests that a successor judge on a case is bound by nonfinal decisions and rulings made by his predecessor.Plaintiff, who was hired by the Utah Department of Transportation (UDOT) to work on different construction projects, filed various claims against UDOT and other contractors on the projects. UDOT moved for summary judgment on claims for breach of contract on the “Arcadia” project and claims seeking consequential damages. Judge Kennedy, the original judge assigned to the case, denied both motions. Judge Kennedy was then replaced in this case by Judge Harris. Judge Harris ultimately dismissed Plaintiff’s claims for breach of contract and consequential damages. Plaintiff filed this interlocutory appeal, arguing that Judge Harris violated the so-called coordinate judge rule, which Plaintiff alleged limits the discretion of a successor judge to revisit decisions of a predecessor. The Supreme Court disagreed, holding (1) a successor judge has the same power to review nonfatal decisions that a predecessor would have had; and (2) Judge Harris did not commit reversible error by dismissing the claims at issue. View "Build v. Utah Department of Transportation" on Justia Law