Justia Utah Supreme Court Opinion Summaries

In this family dispute concerning an inheritance from the mother of two sets of sisters the Supreme Court affirmed the judgment of the trial court ruling that May Harris and Jody Mattena committed a variety of torts in relation to the inheritance and finding them liable for compensatory and punitive damages, holding that the trial court did not err in its rulings during the course of the proceeding.Specifically, the Court held (1) the Liability Reform Act's provision for apportionment of damages, Utah Code 78B-5-818(4)(a), is mandatory only upon a request by a party, and therefore, in absence of a request for apportionment, a trial court acts within its discretion in falling back on the default of joint and several liability; and (2) the provision in Utah Code 78B-8-201(2) providing that evidence of a party's wealth or financial condition shall be admissible only after a finding of liability for punitive damages has been made does not mandate bifurcation of a punitive damages trial in a case in which no party sought to introduce evidence of wealth or financial condition, and the introduction of such evidence is not required as a prerequisite to the availability of a punitive damages award. View "Biesele v. Mattena" on Justia Law

The Supreme Court reversed the judgment of the district court granting summary judgment in favor of Defendant on grounds that Plaintiff's malpractice action was barred by the statute of limitations, holding that Plaintiff's claim was timely filed.In his complaint, Plaintiff alleged that he was convicted of two felonies due to the malpractice of Defendant, his trial counsel. After Plaintiff hired new counsel he secured a new deal that replaced his two felony convictions and three misdemeanor convictions. At issue in this case was when Plaintiff's cause of action accrued. The district court concluded that Plaintiff's malpractice action was untimely filed. The Supreme Court affirmed, holding that Plaintiff's malpractice claim accrued at the conclusion of his criminal case when he pled guilty to three misdemeanors, and not at the time the jury first returned its guilty verdict, and therefore, Plaintiff's malpractice action was filed within the statute of limitations. View "Thomas v. Hillyard" on Justia Law

The Supreme Court affirmed the district court's alimony determination in this divorce action, holding that none of Appellant's alleged errors constituted an abuse of the district court's discretion or were plainly incorrect.Because the parties in this case, Nelson Gardner and Christina Gardner, could not agree on the proper terms of Nelson's alimony obligation to Christina, the matter went to trial. The district court determined that Christina was entitled to alimony but, because of her extramarital sexual affairs, the court reduced Christina's alimony award in amount and duration. Christina appealed, alleging five assignments of error. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in determining that Christina's conduct constituted fault or in establishing the terms of her alimony award; (2) Nelson failed to establish that the district court's failure to consider relevant tax consequences constituted a harmful error; and (3) the district court did not abuse its discretion in declining to award attorney fees to Christina. View "Gardner v. Gardner" on Justia Law

The Supreme Court set aside orders from the Public Service Commission in two related cases, holding that the Commission did not have the authority to impose "interim" rates as an element of the energy balancing account procedures described in Utah Code 54-7-13.5.The Commission issued an order eliminating an "energy balancing account" (EBA) rate processes to PacifiCorp, an electric power provider, and later issued an order adopting the recommendation of the Division of Public Utilities that interim rates be reinstated in the EBA mechanism. After PacifiCorp submitted its 2018 EBA filing that proposed to recover EBA costs in the amount of $28 million on an interim basis the Commission issued an order imposing interim rates. Certain consumer groups challenged the Commission's interim rate orders. The Supreme Court set aside the orders, holding that the interim rates were imposed without a requirement that PacifiCorp prove by substantial evidence that the costs incorporated in the rates were prudently incurred or just and reasonable, which violates the controlling standard set forth in section 54-7-13.5(2)(e)(ii). View "Utah Office of Consumer Services v. Public Service Commission of Utah" on Justia Law

In this case arising from a severe injury Levi Rutherford sustained when he skied into a patch of machine-made snow the Supreme Court declined Defendant's invitations to hold that Plaintiffs' claims were barred by a release of liability signed by Levi's father or, alternatively, Utah's Inherent Risks of Skiing Act, Utah Code 78B-4-401 to -404 (the Act), holding that the district court correctly denied Defendant's motion for summary judgment.Specifically, the district court held (1) the preinjury release signed by Levi's father was unenforceable; and (2) pursuant to Clover v. Snowbird Ski Resort, 808 P.2d 1037 (Utah 1991), summary judgment was not appropriate as to Plaintiff's claims under the Act. The court of appeals affirmed. The Supreme Court affirmed the court of appeals with respect to the preinjury release, holding that the release was void as against public policy and affirmed the court of appeals to the extent that it chose to apply Clover to the facts of this case but remanded for a determination in accordance with this Court's clarified implementation of Clover's holding. View "Rutherford v. Talisker Canyons Finance, Co." on Justia Law

The Supreme Court affirmed Defendant's conviction of three counts of possession of a firearm by a restricted person in violation of Utah Code 76-10-503(3), holding that the district court did not err in refusing the instruct the jury on an innocent possession defense.A jury convicted Defendant of violating section 76-10-503(3) after police officers responding to a domestic complaint found Defendant in his backyard carrying a rifle. Before trial, Defendant requested an innocent possession jury instruction, but the district court denied the request. On appeal, Defendant argued that the felon-in-possession statute included an innocent possession defense. The Supreme Court disagreed, holding (1) the felon-in-possession statute does not implicitly provide an innocent possession defense; and (2) case law does not require an innocent possession defense. View "State v. Sanders" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding the ruling of the district court that orange construction netting that was strung across a public walking trial was an open and obvious danger and that the company that strung the netting across the trail owed Plaintiff no duty of care with respect to the netting, holding that, under the open and obvious danger rule, Defendant owed Plaintiff no duty of care.When Plaintiff chose to step over the netting in this case her foot got caught in the netting and she fell to the ground, suffering injuries to her shoulder and arm. Plaintiff filed a negligence action against Defendant seeking damages for her injuries. The district court granted summary judgment for Defendant, concluding that Defendant did not owe Plaintiff a duty of care under the open and obvious danger rule. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Plaintiff did not meet her burden in persuading the Court to overturn Hale v. Beck stead, 116 P.3d 263 (Utah 2005), and abandon the open and obvious danger rule; and (2) under the open and obvious danger rule, Defendant owed Plaintiff no duty of care. View "Coburn v. Whitaker Construction Co." on Justia Law

The Supreme Court reversed the order of the district court granting Defendant's motion for summary judgment on the complaint filed by Metropolitan Water District of Salt Lake and Sandy (Metro) seeking injunctive relief and other claims regarding Defendant's improvements to his property, in violation to Metro's regulations, on the grounds that Metro's claims were not yet ripe, holding that the parties' claims were ripe.Metro was a quasi-governmental entity known as a limited purpose local district, created for the purpose of operating the Salt Lake Aqueduct (SLA). Metro owned land in fee and had various easements along the SLA corridor, and one of those easements crossed Defendant's backyard. When Defendant made improvements to his property in violation of Metro's regulations over non-Metro district use of SLA corridor lands such as Defendant's, Defendant brought this lawsuit. The district court dismissed Metro's claims as not ripe, finding that determining whether Defendant had unreasonably interfered with the easement was speculative. The Supreme Court reversed, holding that because the parties had present and competing interests in the land at issue and because Metro claimed Defendant was currently violating its alleged regulatory authority, the issues presented in this case were ripe. View "Metro Water District of Salt Lake & Sandy v. Sorf" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of one count of threatening with or using a dangerous weapon in a fight or quarrel, holding that there was no error in the district court's judgment.Defendant, a detective with the Unified Police Department, was bird hunting when he angrily confronted another hunter's group with his service weapon drawn and held at his side. On appeal, Defendant argued that the district court erred in treating the relevant statute's exception for persons acting in self-defense and peace officers in performance of their duties as affirmative defenses rather than elements of the offense. The Supreme Court affirmed, holding (1) under Utah Code 76-10-506, self-defense and acting as a peace officer in performance of duties are affirmative defenses, not elements of the offense; (2) the declaration from a juror submitted by Defendant in support of his motion for a new trial was inadmissible under Utah R. Evid. 606(b); and (3) the district court's deadlock instruction was not unconstitutionally coercive. View "State v. Bess" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing on summary judgment Plaintiff's claims against Box Elder County and the Box Elder County Sheriff's Office, including claims of violations of his rights to due process and bail, holding that the court did not err in dismissing the bail clause claims but erred in dismissing the due process claims.Plaintiff was held in the Box Elder County Jail for seventeen days on a probable cause determination that he was driving under the influence, but no evidence showed that he was actually driving impaired, and Plaintiff was never brought before a judge for his initial appearance or formally charged with any crimes. The district court concluded that Plaintiff had not suffered a flagrant violation of his constitutional rights and that he could not identify a specific municipal employee who had violated his rights. The Supreme Court held (1) Plaintiff's bail clause claims were properly dismissed because Plaintiff failed to demonstrate that the bail clause was self-executing; but (2) the court incorrectly applied the standard for determining when a municipal employee is liable for damages for a constitutional violation in dismissing Plaintiff's due process claims. View "Kuchcinski v. Box Elder County" on Justia Law