Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the district court dismissing Plaintiff's medical malpractice claim against the University of Utah, holding that the district court properly found that Plaintiff's notice of claim was untimely.Plaintiff sought damages for injuries she suffered during a surgery performed by a University of Utah School of Medicine professor at LDS Hospital. Under the Utah Governmental Immunity Act (UGIA), Plaintiff was required to give notice of her claim to the State within one year of the date Plaintiff knew or should of known that she had a claim against a State entity or employee. On appeal, Plaintiff argued that her notice of claim was timely because it was filed within one year of when she knew or should have known she had a claim against the University. The Supreme Court disagreed, holding (1) Plaintiff had sufficient information to put a reasonable person on notice that her claim might be against the State, instead of LDS Hospital; (2) because Plaintiff had reason to inquire long before she filed her notice of claim, her notice was untimely under the UGIA; and (3) Plaintiff's arguments based on the doctrine of res judicata and the Open Courts provision of the Utah Constitution were without merit. View "Amundsen v. University of Utah" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the tax court allowing a second set of deductions sought by Robert and Wendy Steiner on their tax returns but disallowing the first set of deductions, holding that neither set of deductions was mandated by the United States Constitution or the Utah Tax Code.The Utah State Tax Commission disallowed the tax deductions claimed the Steiners on their tax returns. The Steiners challenged that determination in the tax court, asserting that the Dormant Commerce Clause and the Dormant Foreign Commerce Clause mandated the Utah allow their claimed deductions relating to income earned in the United States but outside of Utah and income earned in foreign countries. The Steiners cited Utah Code 59-10-115(2) in support of their latter claim. The tax court agreed in part with the Steiners. The Supreme Court disagreed, holding that the Steiners were not entitled to their claimed deductions. View "Steiner v. Utah State Tax Commission" on Justia Law

In this dispute between a homeowner's association (HOA) and a group of landowners (WDIS) within the HOA's boundaries, the Supreme Court reversed the district court's dismissal of WDIS's quiet title claim and the court's res judicata determination without reaching the merits, holding that no statute of limitations applied to the quiet title claim and that the HOA failed adequately to brief the res judicata issue.At the district court level WDIS brought an action to quiet title in its properties against the HOA, seeking a judicial declaration that its properties were not encumbered by the HOA's covenants and restrictions. In dismissing the action, the district court determined that it was barred by the statute of limitations and that the doctrine of res judicata precluded WDIS from challenging certain encumbrances enacted in 1990. The Supreme Court reversed, holding (1) because WDIS was able to establish a prima facie case of quiet title without first receiving some other relief from the court no statute of limitations applied to WDIS's quiet title claim; and (2) the HOA failed adequately to brief the res judicata issue. View "WDIS, LLC v. Hi-Country Estates Homeowners Ass'n" on Justia Law

The Supreme Court vacated the judgment of the district court dismissing Plaintiffs' complaint against Defendants for lack of personal jurisdiction, holding that the Utah Nonresident Jurisdiction Act compels adoption of the conspiracy theory of jurisdiction and that the case must be remanded for the district court to reexamine the claims and contacts and to apply the jurisdictional tests announced here.Plaintiffs sued Merrill Lynch, Pierce, Fenner & Smith, Goldman Sachs & Co., and related entities (collectively Defendants) for violations of the Utah Pattern of Unlawful Activity Act. Defendants moved to dismiss the complaint for lack of personal jurisdiction. The district court analyzed Plaintiffs' claims against Defendants collectively without analyzing the nature of each individual defendant's contacts as they related to each individual plaintiff's claims. The Supreme Court vacated the judgment, holding (1) because the district court analyzed Plaintiffs' claims and Defendants' contacts collectively, it may have distorted its analysis; and (2) Utah now recognizes a conspiracy theory of jurisdiction, and this case must be remanded to the district court with instruction to assess the conspiracy theory of jurisdiction. View "Raser Technologies, Inc. v. Morgan Stanley & Co." on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Plaintiffs' malpractice claim against Defendant, their attorney, as untimely, holding that Plaintiffs' claim was timely.Plaintiffs lost their opportunity to collect $874,805.68 owed to them in a bankruptcy proceeding when Defendant failed to file Plaintiffs' nondischargeability claim before the expiration of the statute of limitations. Plaintiffs later brought this malpractice action against Defendant. The district court dismissed the claim as untimely, finding that the statute of limitations had expired four years after Defendant missed the filing deadline for the nondischargeability claim. The Supreme Court reversed, holding that the malpractice claim did not accrue until the bankruptcy court confirmed the final distribution plan, and therefore, Plaintiffs' claim was timely. View "Moshier v. Fisher" on Justia Law

The Supreme Court affirmed the order of the Public Service Commission denying PacifiCorp's application for approval of an agreement between PacifiCorp and Monticello Wind Farm, LLC (MWF) for the purchase of wind energy, holding that the Commission was not obligated to approve the agreement under the circumstances of this case.Under Utah and federal law, PacifiCorp and MWF could set the terms for their agreement in one of two ways by either fixing pricing based on PacifiCorp's avoided costs, which would make the contract one negotiated within the Commission's framework, or negotiating their own pricing terms and contractually limiting the scope of the Commission's review. The Commission reviewed the pricing to ensure consistency with PacifiCorp's avoided costs, but the pricing was based on a methodology the Commission had discontinued. The Commission concluded the pricing could not be deemed consistent with PacifiCorp's avoided costs and denied the application. On appeal, MWF asserted that the parties opted out of the Commission's framework, and therefore, the Commission was obligated to approve the agreement. The Supreme Court disagreed, holding that this was an agreement the Commission could reject if it obligated PacifiCorp to purchase energy at a price higher than its avoided costs. View "Monticello Wind Farm, LLC v. Public Service Commission of Utah" on Justia Law

The Supreme Court affirmed the court of appeals' decision reversing the district court's order granting Provo City's motion to dismiss this wrongful death suit on the ground that an estate lacks the legal capacity to assert a claim sounding in wrongful death, holding that the district court erred in dismissing the case on the basis of a lack of capacity.Helen Faucheaux died of a drug overdose in an incident in which Provo City police officers were dispatched to her home. Faucheaux's heirs brought a wrongful death suit against the City. The caption of the complaint listed "The Estate of Helen M. Faucheaux" as the plaintiff. The district court dismissed the case on the ground that an estate lacks the legal capacity to assert a claim sounding in wrongful death. The court of appeals reversed. The Supreme Court affirmed on alternative grounds, holding (1) the caption of a complaint has no controlling significance, and because the complaint made clear that the action was being pursued by the personal representative on behalf of the heirs the district court erred in dismissing the case on the basis of a lack of capacity; and (2) even if this action had been initiated by the estate, the estate's lack of capacity could have been corrected by substitution. View "Estate of Faucheaux v. Provo City" on Justia Law

The Supreme Court dismissed this petition for extraordinary relief asserting that the actions of Governor Gary R. Herbert, Lieutenant Governor Spencer J. Cox, and the Utah Legislature in replacing a citizens' initiative approved by Utah voters that legalized medical cannabis and replacing the initiative with H.B. 3001 were unconstitutional, holding that some of Petitioners' arguments failed on the merits and that the remainder of the petition did not comply with Rule 19 of the Utah Rules of Appellate Procedure.The day H.B. 3001 passed, some of the Petitioners filed a referendum application with the Lieutenant Governor that would have allowed H.B. 3001 to be put to a vote of the people. The Lieutenant Governor denied the petition because he determined one of the referendum sponsors did not meet the applicable statutory requirements and because the Utah House of Representatives and the Utah Senate passed the bill by a supermajority, which made the bill referendum-proof. Petitioners subsequently brought this petition. The Supreme Court dismissed the petition, holding (1) the Governor did not effectively veto Provision 2, and the Two-Thirds Provisions of the Utah Constitution and Utah Code applied to the legislation here; and (2) the rest of the petition is dismissed without prejudice for failure to comply with Rule 19. View "Grant v. Governor Gary R. Herbert" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court denying Defendant's motion to reinstate his time to appeal his conviction under Utah R. App. P. 4(f), holding that Defendant did not satisfy his burden of proving that he was deprived of the right to appeal through no fault of his own.Defendant was convicted of multiple counts of securities fraud. After he was sentenced Defendant filed a pro se notice of appeal and a docketing statement. The court of appeals dismissed his appeal because Defendant failed to submit a brief by the filing deadline. Twelve years later, Defendant filed a motion to reinstate his time to appeal, arguing that the sentencing court failed to inform him of his right to counsel on appeal in his sentencing hearing, and therefore, he was deprived of his right to appeal. The district court denied the motion. The court of appeals reversed. The Supreme Court reversed, holding that the sentencing court was under no legal obligation to inform Defendant of his right to appellate counsel, and as a result, the court was not at fault for the dismissal of Defendant's direct appeal. Therefore, relief under 4(f) was not warranted. View "State v. Stewart" on Justia Law

The Supreme Court reversed the judgment of the district court denying the petition filed by Petitioners, a same-sex married couple and a woman and her husband requesting that the court validate their agreement that the woman act as a gestational surrogate for the couple, holding that Utah Code 78B-15-802(2)(b), which precludes same-sex male couples from obtaining a valid gestational agreement, is unconstitutional.A married couple, both men, entered into an agreement with a woman and her husband to have the woman act as a gestational surrogate to carry a fertilized embryo that contained the genetic material of one of the couple. This type of gestational agreement is not enforceable in Utah unless it is validated by a tribunal, and a court may not validated the agreement if medical evidence is not presented showing that the "intended mother" is unable to bear a child or will suffer health consequences if she does. Petitioners filed a petition requesting that the district court validate their gestational agreement, but the court denied the petition because neither of the intended parents were women. The Supreme Court reversed, holding that the statute is unconstitutional and that the unconstitutional subsection should be severed. The Court then remanded this case for further proceedings. View "In re Gestational Agreement" on Justia Law