Justia Utah Supreme Court Opinion Summaries

Utah Code 35-1-65, which provides that an injured worker who is temporarily totally disabled shall not receive compensation benefits over a period of eight years from the date of the injury, does not operate as an unconstitutional statute of repose under the Open Courts Clause of the Utah Constitution.Petitioner suffered a back injury while working for the Granite School District in 1982. An impartial medical panel concluded that Petitioner’s injury was the medical cause of a subsequent surgery in 2014, but an administrative law judge (ALJ) with the Utah Labor Commission denied Petitioner’s request for temporary total disability compensation on the ground that more than eight years had elapsed since the date of the injury. The Appeals Board of the Commission affirmed. The Supreme Court affirmed, holding (1) section 35-1-64 does not abrogate any previously existing remedy and so is not subject to an Open Courts Clause challenge; and (2) the Workers’ Compensation Act is an adequate substitute remedy for Petitioner’s common law tort of action. View "Petersen v. Utah Labor Commission" on Justia Law

The Supreme Court dismissed Appellant’s appeal of the denial of his motion to withdraw his guilty plea to aggravated murder and other offenses and no contest plea to three counts of attempted aggravated murder. The district court denied the motion on the ground that the Plea Withdrawal Statute, Utah Code 77-13-6, provides that a “request to withdraw a plea of guilty or no contest…shall be made by motion before sentence is announced.” On appeal, Defendant challenged the constitutionality of the statute and contended that he received ineffective assistance of counsel when he entered the plea agreement. The Supreme Court held (1) the jurisdictional bar imposed by the Plea Withdrawal Statute does not deprive a defendant of his constitutional right to an appeal; and (2) Appellant did not timely move to withdraw his pleas, and therefore, Appellant forfeited his right to direct appeal. View "State v. Allgier" on Justia Law

The one-mile stretch of the Weber River at issue in this case is a “navigable water” under the Public Waters Access Act, and therefore, the public has a statutory right to recreational use to that stretch of the river.Utah Stream Access Coalition (USAC) filed this suit seeking a declaration that USAC has a right to use for recreation a one-mile stretch of the Weber River. USAC sought an injunction barring property owners and state officials from interfering with its members’ recreational use rights. The district court concluded that the disputed section of the river was navigable and issued an injunction preventing landowners and state officers from interfering with the recreational use rights of the public on this stretch of the river. The Supreme Court affirmed the district court determination that the disputed segment of the Weber River is navigable water under the Act, holding that there was sufficient evidence to support the determination that the relevant stretch of the river was commercially useful on a regular basis and not merely in an occasional season of high water. View "Utah Stream Access Coalition v. Orange Street Development" on Justia Law

The Supreme Court affirmed the holding in Gailey v. State, 379 P.3d 1278, that the Plea Withdrawal Statute “does not on its face violate the constitutional right to appeal” but also decided an issue that the Gailey majority did not reach, holding that Utah’s Plea Withdrawal Statute, Utah Code 77-13-6, is constitutional as applied because the statute does not foreclose an appeal but simply sets a rule of preservation and imposes the sanction of waiver of the issue on appeal for the failure to follow that rule.Defendant pled guilty to aggravated murder and aggravated kidnapping. Defendant attempted to withdraw his guilty plea by submitting a pro se letter to the district court. Defendant’s subsequently acquired counsel, however, successfully moved to withdraw Defendant’s pro se motion. Defendant appealed, seeking to set aside his guilty plea. Specifically, Defendant argued that the district court erred in accepting his plea, that his counsel provided ineffective assistance, and that the Plea Withdrawal Statute is unconstitutional because it infringes on his right to appeal under Utah Const. art. I, 12. The Supreme Court affirmed, holding that Defendant’s constitutional challenges to the statute failed. View "State v. Rettig" on Justia Law

The Supreme Court affirmed the court of appeals’ decision to uphold the district court’s grant of summary judgment to Fire Insurance Exchange in this dispute over attorneys fees.In the underlying action, Fire Insurance’s action sought a declaratory judgment to determine whether the claim filed by Insured, who was named as a defendant in a personal injury case, was covered under Insured’s policy. The court of appeals ultimately held that the claim was covered. Insured filed a counterclaim seeking attorney fees for the declaratory judgment action, arguing that it was brought in bad faith. The district court concluded that Fire Insurance’s denial of Insured’s claim was reasonable because the coverage issue was “fairly debatable.” The court of appeals affirmed. The Supreme Court affirmed, holding that Insured’s claim that Fire Insurance did not fairly evaluate his claim and unreasonably rejected it failed. Therefore, summary judgment was properly granted to Fire Insurance. View "Fire Insurance Exchange v. Oltmanns" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding the district court’s grant of summary judgment to Defendants - a physician and pharmacy - in this case filed by Plaintiff alleging that Defendants overprescribed medication. The district court determined that, because Plaintiff had failed to designate any expert on the applicable standards of care until the day on which the district court had scheduled the summary judgment hearing, the late-designated expert should be excluded, and without expert testimony Plaintiff would be unable to show that either the physician or the pharmacy had violated the applicable standard of care. The court of appeals affirmed. The Supreme Court affirmed, holding that Plaintiff failed to preserve any of the issues she appealed. View "Baumann v. Kroger Co." on Justia Law

The Supreme Court affirmed the district court’s grant of Patricia and Robert Porenta’s marital home to Patricia in this case involving a fraudulent transfer of the home to Robert’s mother (Mother).During the divorce proceedings of Patricia and Robert, Robert transferred his interest in the couple’s marital home to Mother with the intent to avoid Patricia’s claim to the home. Robert subsequently died, and the divorce case was dismissed for lack of jurisdiction. Thereafter, Patricia filed this action against Mother alleging that the transfer was fraudulent under the Utah Fraudulent Transfer Act. The district court granted the marital home to Patricia. The Supreme Court affirmed, holding (1) the Utah Fraudulent Transfer Act requires an ongoing debtor-creditor relationship when a claim under the Act is filed, and the debtor-creditor relationship was in this case was not extinguished when Robert died because an ongoing debtor-creditor relationship existed between Patricia and Robert’s estate; and (2) the trial court did not err in granting Patricia the entire marital home rather than money damages, but the matter is remanded for a determination of the current status of title. View "Porenta v. Porenta" on Justia Law

The Supreme Court affirmed the judgment of the juvenile court adjudicating D.G. and R.G. delinquent for committing aggravated sexual assault. The juvenile court denied the motions filed by D.G. and R.G. to suppress their post-Miranda statements regarding the sexual assault to a detective during an interview, and both interviews with the detective regarding the sexual assault were introduced at trial. D.G. and R.G. appealed, arguing that the juvenile court erred in denying the motion to suppress their post-Miranda statements. The Supreme Court affirmed, holding (1) the Miranda warnings given to D.G. and R.G. were sufficient according to the standards set by this court and the United States Supreme Court; and (2) both D.G. and R.G. knowingly and voluntarily waived their Miranda rights. View "In re R.G." on Justia Law

The Supreme Court did not reach the merits in this matter where Father appealed the district court order awarding Mother attorney fees and costs for the underlying juvenile court proceedings for lack of jurisdiction and awarded Mother reasonable attorney fees and costs on appeal. The juvenile court denied Father’s petition to terminate Mother’s parental rights and granted Mother custody of the parties’ minor children. The court also ordered Father to pay all fees and costs incurred by Mother. When jurisdiction over the case had been transferred to the district court, the court granted Mother’s motion for attorney fees. Father filed a motion to alter or amend under Utah R. Civ. P. 59 challenging the award. The Supreme Court held (1) the district court lacked the authority to rule on the merits of the Rule 59 motion because it was not timely filed, and therefore, the earlier order of the district court was the final judgment on the underlying matter of attorney fees and costs; (2) the Supreme Court lacked jurisdiction to rule on the merits of this case; and (3) Mother is awarded reasonable attorney fees and costs on appeal. View "Smith v. Smith" on Justia Law

The court of appeals erred in concluding that exceptional circumstances merited review of an issue not preserved in the trial court and not argued on appeal.Defendant was found guilty of murder. On appeal, the court of appeals asked for supplemental briefing on an issue that was not argued by the parties. After supplemental briefing, the court of appeals reversed Defendant’s conviction, concluding that a homicide by assault jury instruction was erroneous. In so ruling, the court decided that the exceptional circumstances exception to the preservation rule permitted the court to examine the unpreserved and likely invited error. The Supreme Court reversed, holding that the exceptional circumstances exception to the preservation rule did not apply in this case. View "State v. Johnson" on Justia Law