Justia Utah Supreme Court Opinion Summaries

After the death of Beverly Davies in 2015, her granddaughter filed a petition in the Utah district court to probate Davies’s will just before the three-year anniversary of Davies’s death. The petition sought to have the will declared valid and to appoint the granddaughter as personal representative. However, after nearly three years of inactivity, the court dismissed the petition without prejudice for failure to prosecute. Almost a year after this dismissal, the granddaughter refiled her petition, this time invoking Utah’s Savings Statute, which generally allows a new action to be commenced within one year of a non-merits dismissal if the original action was timely.Davies’s other grandchildren objected to the refiling and moved for partial summary judgment in the Fourth District Court, arguing that the new petition was untimely under Utah Code section 75-3-107, which requires probate proceedings to be commenced within three years of the decedent’s death. They contended that the Savings Statute did not apply to this probate timing statute. The district court disagreed, holding that the Savings Statute protected the granddaughter’s otherwise untimely petition and denied the motion for partial summary judgment.The Supreme Court of the State of Utah reviewed the interlocutory order. The court held that the Savings Statute does not apply to the three-year time limitation in section 75-3-107 of the Utah Uniform Probate Code. The court reasoned that the plain language of the Probate Code prohibits commencing probate proceedings more than three years after death, and this prohibition conflicts with the general grace period provided by the Savings Statute. As a result, the Supreme Court reversed the district court’s denial of partial summary judgment and remanded for further proceedings, concluding that the granddaughter’s second petition was prohibited. View "In re Estate of Davies" on Justia Law

A behavioral healthcare practice employed four therapists who, while still working there, explored job opportunities with another provider. During this process, the prospective employer requested and received information from the therapists, including details about their employment agreements, client lists, and insurance credentialing. The therapists had previously signed confidentiality agreements with their original employer, which defined client information as confidential. After the therapists joined the new provider, a significant number of clients followed them, and the original practice eventually closed.The original employer first sued the therapists for breaching their agreements and settled that case. It then brought a separate lawsuit against the new provider, alleging misappropriation of trade secrets under Utah’s Uniform Trade Secrets Act. The claim centered on the new provider’s alleged use of confidential client information to facilitate onboarding clients, set therapist compensation, and prepare for insurance billing. Both parties moved for summary judgment in the Third District Court, Salt Lake County. The district court granted partial summary judgment to the original employer on liability, finding that trade secrets existed and had been misappropriated, but left damages and exemplary damages for trial. The court denied the new provider’s motion for summary judgment, concluding that the original employer had met its burden of production.The Supreme Court of the State of Utah reviewed the interlocutory order. It held that the original employer failed to present a legally sufficient evidentiary basis for its damages theory, a necessary element of a trade secrets claim. The court found no evidence that the new provider’s receipt of client information caused the original employer’s losses, as clients left primarily to follow their therapists. The court reversed the district court’s denial of summary judgment for the new provider and set aside the partial summary judgment for the original employer. View "Military and Veteran Counseling Center, LLC v. Feller Behavioral Health PLLC" on Justia Law

Two individuals who were active in efforts to incorporate the community of Erda, Utah, alleged that three other residents defamed them and placed them in a false light. The plaintiffs had been involved in organizing the incorporation, including gathering signatures and working with property owners. After the incorporation was approved by voters, a local ranch company filed lawsuits alleging fraud in the incorporation process, specifically that signatures had been misused or altered. The defendants, in various public forums and on social media, accused the plaintiffs of fraud, forgery, and other misconduct related to the incorporation and subsequent community disputes.The Third District Court in Tooele County dismissed the plaintiffs’ claims. It found that the statements made by two defendants were not capable of defamatory meaning, were privileged, and that the false light claims failed for the same reasons. For the third defendant, the court granted judgment on the pleadings under Utah’s Anti-SLAPP Act, concluding that his statements were protected as participation in the process of government and that the lawsuit was intended to chill such participation.The Supreme Court of the State of Utah reversed and remanded. It held that at least some of the statements by the first two defendants were capable of defamatory meaning and were not constitutionally protected opinions. The court also held that it was improper to dismiss the claims on privilege grounds at the motion to dismiss stage, as privilege is an affirmative defense that must be raised and supported by the defendant. Regarding the third defendant, the court held that the Anti-SLAPP Act did not apply because his statements were not made while participating in the process of government as defined by the statute. The court ordered that the case proceed on all claims. View "Mathews v. McCown" on Justia Law

In 1997, an individual applied to the Utah Division of Water Rights to divert water from a surface source in the Weber Basin for irrigation and livestock purposes. The application was met with protests from the Weber Basin Water Conservancy District and the Utah Division of Wildlife Resources, among others. After a hearing in 1998 and sporadic communications over the next two decades, the Utah State Engineer ultimately denied the application in 2018. The applicant sought judicial review in the Second District Court, arguing that the denial was improper because the water source contained unappropriated water, the application would not interfere with existing rights, and the application’s 1997 filing date should give it priority.While the case was pending in the Second District Court, the applicant died. His counsel moved to substitute the estate’s personal representative as the plaintiff under Utah Rule of Civil Procedure 25(a)(1). The district court denied the motion, holding that the claim did not survive the applicant’s death because he had no perfected property right and any inchoate right was not mentioned in his will. The court also found that Utah’s general survival statute did not apply, and dismissed the case. The estate appealed.The Supreme Court of the State of Utah reviewed whether the district court erred in denying substitution and dismissing the claim. The court held that the burden was on the movant to show the claim survived death. It found that neither common law nor statute provided for the survival of a claim for judicial review of an administrative denial of a water appropriation application. The court concluded that the claim abated upon the applicant’s death and affirmed the district court’s dismissal. View "Marriott v. Wilhelmsen" on Justia Law

A 34-year-old man engaged in a months-long sexual relationship with a 16-year-old girl, whom he met online. The relationship involved sexual encounters, the exchange of nude photographs, and the provision of marijuana and alcohol to the minor. The man used online messaging applications to communicate and arrange meetings. The investigation began after the girl reported the relationship to police, but she could not provide identifying information about the man beyond his online aliases. State detectives, working as part of a federal task force, requested that federal officers use federal administrative subpoenas to obtain electronic records from service providers, which ultimately identified the suspect.The Second District Court in Davis County denied the defendant’s motion to suppress the electronic records, finding that the evidence was lawfully obtained through federal subpoenas. The court also admitted evidence from the defendant’s Summit County residence, including items corroborating the girl’s account. At trial, the jury convicted the defendant on multiple counts, including human trafficking of a child, sexual exploitation of a minor, and distribution of a controlled substance. The court partially granted a post-trial motion to arrest judgment but left the most serious convictions intact. The defendant appealed.The Supreme Court of the State of Utah held that Utah’s Electronic Information or Data Privacy Act (EIDPA) does not require suppression of evidence lawfully obtained by federal officers and shared with state officers, and that the Utah Constitution was not violated by the use of such evidence. The court vacated the conviction for human trafficking of a child, holding that the statute requires proof that something of value was actually given or received in exchange for a sexual act, not merely offered. The court affirmed the convictions for sexual exploitation of a minor and distribution of a controlled substance, and found that any error in admitting certain evidence was harmless. View "State v. Andrus" on Justia Law

Two companies each owned a one-half undivided interest in the subsurface estate (sand, gravel, and clay) of a small parcel of land, while one of them, Toll, also owned the surface estate. Toll developed the parcel as part of a larger project, excavating soil from parts of the parcel and using it as fill on the same parcel to achieve the desired grade and density. The other company, Genesis, alleged that Toll had removed and transferred soil from the parcel to third parties without compensation, and also claimed that Toll’s use of the soil on-site interfered with Genesis’s rights.After discovery, Toll moved for summary judgment in the Fourth District Court, Provo, arguing there was no evidence it had exported soil from the parcel and that Genesis was not entitled to compensation for soil used on-site. Genesis conceded it lacked evidence of off-site removal but argued that a jury could infer such removal due to Toll’s exclusive control of relevant information. Genesis also argued it was entitled to compensation for Toll’s on-site use of the soil, claiming this interfered with its rights or unjustly enriched Toll. The district court granted summary judgment to Toll, finding no evidence of off-site removal and holding that, under Utah law and persuasive Washington precedent, a surface owner may use soil on-site without compensating the subsurface co-owner unless the soil is exported.On direct appeal, the Supreme Court of the State of Utah affirmed the district court’s decision. The Court held that Genesis failed to provide evidence supporting its claim that Toll removed soil from the parcel, and that mere speculation or attacks on Toll’s credibility were insufficient to create a genuine issue of material fact. The Court further held that Genesis was not entitled to compensation for Toll’s on-site use of the soil, as such use did not constitute actionable interference with Genesis’s subsurface rights under the deed or common law. The summary judgment in favor of Toll was affirmed. View "Genesis Aggregates B v. Toll Southwest" on Justia Law

A group of residents sought to challenge a Tooele County zoning ordinance that changed the designation of a parcel of land in Erda from agricultural to planned-community zoning, enabling its development. The residents, acting as referendum sponsors, attempted to gather enough signatures to place the ordinance on the ballot for possible repeal, aiming to preserve the land’s agricultural status. Their efforts were complicated by the COVID-19 pandemic and related executive orders, which they argued hindered their ability to collect signatures. Despite requesting permission to use electronic signatures, their request was denied, and they ultimately failed to meet the required signature threshold as determined by the County Clerk.The sponsors then filed suit in the Third District Court, Tooele County, against both the County and the Governor, challenging the signature threshold and the denial of electronic signatures. During the litigation, the area containing the property was incorporated as the City of Erda, transferring land-use authority from the County to the new city. The district court granted summary judgment to the County, finding the Clerk had correctly applied the signature threshold, and granted judgment on the pleadings to the Governor, rejecting the constitutional claims. The sponsors appealed.The Supreme Court of the State of Utah reviewed the case and determined that it was moot. The court held that, because the property is now within the City of Erda and subject to its zoning authority, a referendum repealing the Tooele County ordinance would have no legal effect on the property’s current zoning. The court found that it could not provide meaningful relief to the sponsors, as Erda has enacted its own zoning ordinances for the property. Accordingly, the court dismissed the appeal as moot. View "Haney v. Tooele County" on Justia Law

Two companies each owned a one-half undivided interest in the subsurface estate (specifically, sand, gravel, and clay) of a small parcel of land, while one of them also owned the entire surface estate. The surface owner developed the parcel by excavating soil and using it as fill on the same parcel to achieve the desired grade and density for construction. The subsurface co-owner sued, alleging that the surface owner had removed and transferred soil off-site without compensation, and also claimed entitlement to compensation for the on-site use of the soil, arguing that such use interfered with its rights.The Fourth District Court reviewed the case after discovery. The surface owner moved for summary judgment, presenting evidence that no soil was removed from the parcel and that all excavated soil was used on-site. The subsurface co-owner conceded it had no evidence that soil was exported off-site but argued that a jury could infer such removal due to the surface owner’s exclusive control of relevant information. The district court found no genuine dispute of material fact regarding off-site removal and held that, under Utah law and persuasive Washington precedent, a surface owner is entitled to use soil for on-site development without compensating the subsurface owner, unless the soil is exported. The court granted summary judgment and dismissed all claims.On direct appeal, the Supreme Court of the State of Utah affirmed the district court’s decision. The Court held that the subsurface co-owner failed to provide evidence supporting its claim of off-site removal, and that the surface owner’s on-site use of soil did not constitute actionable interference with the subsurface rights. The Court clarified that, absent an agreement to the contrary, a surface owner may use subsurface materials for on-site development without owing compensation to a subsurface co-owner, provided there is no interference with the latter’s right to remove those materials. The summary judgment in favor of the surface owner was affirmed. View "State v. Wilcox" on Justia Law

After experiencing shortness of breath and chest pain, Jorge Armenta lost consciousness and his wife called 911. Emergency medical technicians from Unified Fire Authority (UFA) responded, evaluated Armenta, and told him that everything appeared normal, suggesting he had an anxiety attack and did not need to go to the emergency room. A week later, Armenta was hospitalized for a massive heart attack, which resulted in significant and potentially life-shortening heart damage. Armenta filed a negligence suit against UFA, alleging that their failure to properly diagnose and treat him caused his injuries.The Third District Court, Salt Lake County, reviewed UFA’s motion to dismiss, which argued that the Utah Governmental Immunity Act (UGIA) shielded UFA from liability. The district court applied a three-part test, found that UFA’s actions were a governmental function, that immunity was generally waived for such activities, but that an exception for “providing emergency medical assistance” restored immunity. The court dismissed Armenta’s claims against UFA and entered judgment under rule 54(b) of the Utah Rules of Civil Procedure.On direct appeal, the Supreme Court of the State of Utah reviewed the district court’s statutory interpretation and dismissal. The Supreme Court held that the district court erred in its interpretation of the “providing emergency medical assistance” exception under the UGIA. The Court determined that, when read in context with related statutory provisions, the exception applies only to medical assistance provided in response to certain types of emergencies, such as disasters or catastrophic events, not to routine emergency medical responses like the one at issue. Therefore, the UGIA does not immunize UFA from Armenta’s suit. The Supreme Court reversed the district court’s dismissal and remanded the case for further proceedings. View "ARMENTA v. UNIFIED FIRE AUTHORITY" on Justia Law

Talisker Finance, LLC and its affiliates defaulted on a $150 million loan secured by real property, which they had borrowed to develop parcels in Utah. After several loan modifications and assignments, the lenders—Wells Fargo Bank, N.A. and Midtown Acquisitions L.P.—foreclosed on the collateral and purchased it at two sheriff’s sales, where they were the only bidders. The sale proceeds did not satisfy the debt, and the lenders continued to pursue the deficiency. Later, Talisker discovered information suggesting that the lenders, in coordination with a court-appointed receiver, may have taken actions to depress the sale price, including deterring potential bidders and bundling properties in a way that made them less attractive.Talisker filed suit in the Third District Court, Summit County, seeking equitable relief from the deficiency judgments, alleging that the lenders’ conduct during the foreclosure process violated Utah Rule of Civil Procedure 69B(d) and constituted fraud or grossly inequitable conduct. The lenders moved to dismiss, arguing that Talisker had broadly waived any rights or defenses related to the foreclosure process in the loan documents. The district court accepted Talisker’s factual allegations as true for purposes of the motion but concluded that the waivers were enforceable and covered the rights Talisker sought to assert, including those under Rule 69B(d). The court found no unlawful irregularity in the sales and dismissed the complaint.On direct appeal, the Supreme Court of the State of Utah affirmed the district court’s dismissal. The court held that Talisker’s broad and explicit waivers in the loan documents encompassed all rights and defenses related to the foreclosure sales, including the right to challenge the method of sale or seek equitable relief based on alleged unfairness or irregularities. The court concluded that, regardless of the alleged conduct, Talisker had contractually relinquished any basis for relief. View "TALISKER PARTNERSHIP v. MIDTOWN ACQUISITIONS" on Justia Law