Justia Utah Supreme Court Opinion Summaries

In 2018, a group of citizens in Tooele County, Utah, initiated the process to incorporate an area known as the City of Erda. The incorporation process involved several steps, including obtaining signatures from property owners within the proposed area, conducting a feasibility study, and holding a public vote. After the incorporation was certified by the Lieutenant Governor, three landowners within Erda's boundaries—John Bleazard, Mark Bleazard, and Six Mile Ranch Company—challenged the incorporation. They alleged that the incorporation process violated statutory requirements, including that their signatures were misrepresented in the feasibility study request and that the notice of impending boundary action was untimely.The district court in Tooele County denied motions to dismiss the case brought by the City of Erda and the Lieutenant Governor. They had argued that the landowners lacked statutory standing to challenge the incorporation. The court disagreed, finding that the landowners had a legally protectible interest under the Utah Code, which it interpreted as contemplating the possibility of a challenge to an incorporation.The Supreme Court of the State of Utah reversed the district court's decision. The Supreme Court held that the landowners' claim for declaratory relief was non-justiciable because they lacked a legally protectible interest in the controversy. The court found that the landowners did not have a private right of action to enforce the requirements of the incorporation code. The court concluded that the landowners' claim must be dismissed as a matter of law. View "Bleazard v. City of Erda" on Justia Law

In Utah, a group of local citizens sponsored the incorporation of an area in Tooele County to be known as the City of Erda. After the Lieutenant Governor certified Erda’s incorporation, three landowners within Erda’s boundaries challenged the incorporation, alleging statutory violations during the incorporation process. The defendants, Erda and the Lieutenant Governor, moved to dismiss the complaint, arguing that the landowners lacked statutory standing. The district court disagreed and denied their motions to dismiss.The defendants appealed to the Supreme Court of the State of Utah, arguing that the landowners' claim for declaratory relief should be dismissed as it is non-justiciable. The Supreme Court agreed, holding that the landowners’ claim must be dismissed as a matter of law because it is non-justiciable. The court found that under Utah law, a declaratory judgment action is non-justiciable if the plaintiff lacks a protectible legal interest in the controversy. The court concluded that the landowners did not have a protectible legal interest in their claim because the legislature did not grant affected citizens a private right of action to enforce the incorporation code’s requirements. Therefore, the court reversed the district court’s decision. View "Bleazard v. Henderson" on Justia Law

The case involves the trustees of the Stanley and Sandra Goldberg Trusts, C. Leon Nelson and Marilynn Tetrick, who hired legal counsel to assist them in their duties. The same attorneys later defended them in a lawsuit brought by several beneficiaries of the trusts. The jury found that the trustees had breached their fiduciary duties, and the district court entered a judgment against them, most of which was payable to the trusts. The court then removed the trustees and appointed successor trustees. The former trustees, still represented by the same attorneys, asked the court to reduce the amount of the judgment against them. The successor trustees moved to disqualify the former trustees’ attorneys, arguing that a conflict had surfaced under rule 1.9(a) of the Utah Rules of Professional Conduct. The district court agreed and disqualified the attorneys.On appeal, the Supreme Court of the State of Utah reversed the district court's decision. The Supreme Court held that an attorney-client relationship does not automatically arise merely because an attorney represents a trustee. In this case, the attorneys represented the former trustees only, not the trusts, which were not named in the suit. Thus, because the attorneys never represented the trusts in the litigation, rule 1.9(a) does not prevent the attorneys from continuing to represent the former trustees. View "In re Estate of Goldberg" on Justia Law

Weston Bennion was injured when his apartment deck collapsed and subsequently sued his landlord, Dale Stolrow, for negligence. The parties settled, with Bennion agreeing to release Stolrow and his insurer from all claims in exchange for $150,000. The settlement was subject to related subrogation claims and healthcare liens, and Bennion promised to indemnify Stolrow from liability for any such claims and liens. Before making the payment, Stolrow informed Bennion that he intended to distribute the payment in two checks: one payable to Bennion and the other payable to a collection agency that had a healthcare lien on the settlement funds. Bennion objected and filed a motion to enforce the parties’ agreement, arguing that its terms did not allow Stolrow to issue a portion of the settlement funds to a third party.The district court disagreed with Bennion and suggested that Stolrow issue two checks: one jointly to Bennion and the third party for the amount of the lien, and another to Bennion for the remainder of the funds. The court of appeals affirmed the district court’s decision. Bennion then petitioned for certiorari.The Supreme Court of the State of Utah granted certiorari to address whether the court of appeals erred in concluding that the parties’ agreement permitted Stolrow to issue a portion of the settlement funds jointly to Bennion and the third-party collection agency. The court agreed with Bennion, stating that the plain language of the release provides for payment to Bennion in exchange for his release of claims against Stolrow and his assumption of responsibility for third-party liens. Therefore, the court reversed the decision of the lower courts. View "Bennion v. Stolrow" on Justia Law

The case involves Shane Craig Smith, who was arrested in a police sting operation after he attempted to engage in sexual activities with a persona named "Emily," who he believed to be a 13-year-old girl. Smith had met Emily online and had arranged to meet her at a gas station in Lehi, Utah, with the intention of having her perform multiple sex acts in exchange for driving her to California. Smith was charged with various crimes, including attempted child kidnapping, attempted rape of a child, and attempted sodomy of a child. He pled guilty to most of these charges while reserving the right to appeal two issues: whether there was sufficient evidence to bind him over for trial on the attempt charges, and whether he was entrapped as a matter of law.Smith's case was first heard in the district court, where he moved to decline to bind over the counts of attempted rape of a child, attempted sodomy of a child, and attempted kidnapping of a child. He argued that the State’s evidence regarding the attempt crimes did not show that his actions rose beyond solicitation or mere preparation and was therefore insufficient to support probable cause on the “substantial step” element of the attempt statute. The district court denied the motion and bound over all counts for trial. Smith then filed a motion to dismiss all charges on entrapment grounds, which the district court denied. Smith eventually entered a conditional guilty plea to attempted child kidnapping, attempted sodomy of a child, and enticement of a minor, allowing him to appeal the district court’s bindover ruling and entrapment determination.Smith appealed to the Utah Court of Appeals, where he raised two issues: whether there was insufficient evidence to bind over the attempt charges for trial, and whether the district court erred by denying his motion to dismiss all the charges on the basis that he had been entrapped. The court of appeals affirmed the district court’s rulings. Smith then petitioned for certiorari to the Supreme Court of the State of Utah.The Supreme Court of the State of Utah affirmed the decisions of the lower courts. The court found that Smith's actions constituted substantial steps toward the commission of the crimes he was charged with, and that he was not entrapped as a matter of law. The court held that Smith's actions strongly corroborated his intent to commit the crimes, and that the police conduct in the case did not create a substantial risk that an average person would attempt to commit the crimes that Smith attempted. View "State v. Smith" on Justia Law

Nicholas and Julie Kuhar filed a product liability claim against Thompson Manufacturing, a Utah company, seeking compensation for injuries Nicholas sustained when his safety harness failed while he was cleaning rain gutters in New Jersey. This was not the first lawsuit the Kuhars had brought regarding this incident. They had previously sued Thompson and other defendants in New Jersey federal court, alleging that the harness was defective. That suit was unsuccessful, with Thompson being dismissed from the case due to a lack of personal jurisdiction. The Kuhars then refiled their claims against Thompson in Utah.In the New Jersey case, the Kuhars' expert witness was excluded, and the remaining defendants were granted summary judgment. Thompson then moved in the Utah case to preclude the Kuhars from litigating the issue of whether the harness was defective. The district court agreed with Thompson and dismissed the Kuhars' claims. However, the Utah Court of Appeals reversed this decision, concluding that the issue litigated and decided in New Jersey was not identical to the issue Thompson sought to preclude in Utah.The Supreme Court of the State of Utah, however, disagreed with the Court of Appeals. It concluded that the elements of issue preclusion were satisfied. The court clarified that to determine the issue-preclusive effect of the New Jersey federal court’s judgment in this case, the substantive law of New Jersey applies. Under that law, the court concluded that the issue Thompson sought to preclude the Kuhars from litigating—whether the harness was defective—was actually litigated and decided on the merits in the New Jersey court’s summary judgment order. Therefore, the Supreme Court of the State of Utah reversed the decision of the Court of Appeals. View "Kuhar v. Thompson Manufacturing" on Justia Law

The case involves Salt Lake County's challenge to the constitutionality of the Aircraft Valuation Law, which provides a preferred method for determining the fair market value of aircraft for tax purposes. The County argued that the application of the law to Delta Air Lines' aircraft resulted in an assessment below fair market value, violating the Utah Constitution. The County also contended that the law, on its face, violated the Utah Constitution by divesting the Utah State Tax Commission of its power to assess airline property.The Utah State Tax Commission had previously upheld the 2017 assessment of Delta's property, which was calculated according to the Aircraft Valuation Law. The Commission found that the County did not provide clear and convincing evidence that the legislature's preferred method of valuation did not reasonably reflect fair market value.The Supreme Court of the State of Utah rejected the County's arguments. The court held that the County failed to fully utilize the statutory safety valve, which allows the Commission to use an alternative valuation method if the preferred method does not reasonably reflect fair market value. The court also rejected the County's facial challenge to the Aircraft Valuation Law, concluding that the County did not show that the law prohibits the legislature from prescribing a preferred method for valuing aircraft. Therefore, the court affirmed the Commission's decision. View "Salt Lake Co v. Tax Commission" on Justia Law

The case involves the interpretation of Utah's Pretrial Justification Statute and its application to a situation where a defendant, Jon Michael Clara, claimed self-defense after firing his gun at a snowplow that had repeatedly rammed his vehicle. Clara was charged with seven counts of felony discharge of a firearm. He invoked the Pretrial Justification Statute, which allows a defendant to have a claim of self-defense assessed by a judge in a pretrial hearing. At the pretrial hearing, the defendant first has to make a prima facie claim of self-defense, then the prosecution must prove by clear and convincing evidence that the defendant’s use of force wasn't justified.At the pretrial hearing, Clara testified that after being rammed multiple times, he believed the snowplow was making a U-turn to attack again, leading him to fire his gun as a warning. The district court ruled that Clara had made a prima facie claim of self-defense and that the State had not disproved the self-defense claim by clear and convincing evidence. Therefore, the district court dismissed the charges against Clara.The State appealed, arguing that Clara failed to make a prima facie claim of self-defense, as the defendant’s belief in the imminence of the threat wasn’t objectively reasonable. The Supreme Court of the State of Utah, however, affirmed the district court’s ruling, stating that a reasonable person in Clara's position could have believed that the snowplow posed an imminent threat. View "State v. Clara" on Justia Law

This case involved a group of businesses (referred to collectively as Taxpayers) who filed applications for adjustments to the fair market value of their properties for tax year 2020 in the state of Utah. They claimed that their properties' values had decreased due to "access interruption" caused by the COVID-19 pandemic and associated government guidelines, which they argued constituted a circumstance beyond their control under Utah Code section 59-2-1004.6 (the Access Interruption Statute).The Utah State Tax Commission rejected this argument, maintaining that the pandemic did not qualify as an "access interruption event" under the Access Interruption Statute. It reasoned that the statute applies only if access was interrupted due to any of thirteen enumerated events or due to a similar event as determined by the Commission via administrative rule. Because the pandemic neither fit into any of the enumerated categories nor was included in the Commission's administrative rules, the Commission ruled that the statute did not apply.The Supreme Court of the State of Utah agreed with the Commission's reasoning, holding that the Access Interruption Statute allows only the Commission to add to the statute’s list of qualifying circumstances if the Commission determines by rule that the additional event is similar to the events enumerated in the statute. Because the pandemic was not an enumerated event and had not been added by administrative rule, the Supreme Court upheld the Commission's decision. View "Miller Theatres v. Tax Commission" on Justia Law

A dispute arose between SunStone Realty Partners X LLC (SunStone) and Bodell Construction Company (Bodell) over the postjudgment interest rate applied to a domesticated Hawaii judgment in Utah. Following arbitration in Hawaii over construction defects in a condominium development, SunStone obtained a judgment against Bodell exceeding $9.5 million, which it domesticated in Utah. Bodell requested the Utah court to apply Utah's lower postjudgment interest rate instead of Hawaii's higher one. SunStone opposed this, arguing that the Utah Foreign Judgment Act (UFJA) required the application of Hawaii's rate, or alternatively, that their contract or principles of comity mandated the Hawaii rate.The Supreme Court of the State of Utah affirmed the district court's decision to apply Utah's postjudgment interest rate. The court found that the UFJA, which does not specifically address postjudgment interest, instructs Utah courts to treat a foreign domesticated judgment like a Utah judgment for enforcement purposes. Since postjudgment interest serves, at least in part, as an enforcement mechanism, the UFJA requires the imposition of Utah’s postjudgment interest rate. Further, the construction contract did not require the application of the Hawaii postjudgment interest rate. The court did not consider principles of comity because the UFJA mandates a result. View "Sunstone Realty v. Bodell Construction" on Justia Law