Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s conviction of rape of a child, holding that each of Defendant’s claims on appeal failed.Specifically, the Court held (1) this Court declines to consider whether the district court erred in relying upon each of the factors previously articulated in State v. Shickles, 760 P.2d 291 (Utah 1998), to determine the admissibility of Defendant’s previous acts of child molestation because review of this claim was precluded by the invited error doctrine; (2) the district court did not err in admitting evidence of Defendant’s prior acts of child molestation; and (3) Defendant’s claim of ineffective assistance of counsel failed because he did not show that any of counsel’s alleged deficiencies constituted deficient performance and resulted in prejudice. View "State v Ring" on Justia Law

The Supreme Court affirmed the district court’s ruling that Plaintiff, a municipal employee, had forfeited her merit protection status through contract, estoppel, and waiver without reaching the merits of Plaintiff’s claims because she failed to carry her burden of challenging all of the district court’s rulings, each of which was an independent basis for summary judgment.On appeal, Plaintiff argued that Supreme Court precedent allowing a contract in conflict with a statute to survive, provided it does not violate public policy, does not extend to contracts involving government employees. The Supreme Court held that, although it was possible that Plaintiff was correct, Plaintiff was not entitled to relief because she failed to challenge the district court’s ruling that she was equitably estopped from claiming merit status. View "Howick v. Salt Lake City Corp." on Justia Law

The Supreme Court reversed the decision to award prejudgment interest to LeGrand and concluded that Celtic Bank was the prevailing party on the prejudgment interest issues.LeGrand Johnson Construction Company filed an action seeking to enforce its mechanic’s lien on property owned by B2AC, LLC for the unpaid value of construction services, and Celtic Bank, B2AC’s lender, sought to foreclose on the same property after B2AC failed to pay on its loan. The action resulted in a lien for $237,294 and an award of attorney fees and costs. Thereafter, the district court determined that LeGrand’s lien, rather than Celtic Bank’s lien, had priority and awarded LeGrand attorney fees and costs. The court then ruled that LeGrand was entitled to recover eighteen percent in prejudgment and postjudgment interest from Celtic Bank based on LeGrand’s contract with B2AC. The Supreme Court (1) reinforced its holding in Jordan Construction, Inc. v. Federal National Mortgage Ass’n, 408 P.3d 296 (Utah 2017), that prejudgment interest is not available under the 2008 version of the Utah Mechanic’s Lien Act; and (2) vacated the attorney fee award because it was based, in part, on the notion that LeGrand had succeeded in establishing its right to prejudgment interest. View "LeGrand Johnson Construction Co. v. Celtic Bank Corp." on Justia Law

The Supreme Court overruled the relevant portions of State v. Finlayson, 994 P.2d 1243 (Utah 2000), and State v. Lee, 128 P.3d 1179 (Utah 2006), that set forth and recapped the common-law merger test and announced that the controlling test is set forth in Utah Code 76-1-402(1).Defendant was convicted of one count of aggravated assault and one count of aggravated kidnapping. On appeal, Defendant argued that the two convictions should have merged pursuant to State v. Finlayson, P.2d 1243 (Utah 2000), and that his trial counsel rendered ineffective assistance by not asking for an order to that effect. The court of appeals affirmed, holding that trial counsel was not ineffective because the convictions did not, in fact, merge. The Supreme Court affirmed, holding that, in view of the decision announced today, the court of appeals did not err in determining that Defendant’s trial counsel was not ineffective. View "State v. Wilder" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiffs’ complaint against Weber County claiming that the County had violated Utah Code 59-22-103 and 59-2-103.5, which establish the tax exemption for primary residential property.Plaintiffs paid taxes on their primary residence but later learned that the County had not given them the residential exemption. The district court entered a judgment on the pleadings dismissing Plaintiffs’ causes of action, concluding, inter alia, that the assessor acted within the scope of his authority in reclassifying Plaintiffs’ property as “non-primary residential.” In affirming, the Supreme Court held that Plaintiffs’ challenges to the taxes they paid must fall under Utah Code 59-2-1321, which requires taxpayers to point an “error or illegality that is readily apparent from county records.” Because Plaintiffs did not challenge this requirement or show that the alleged errors or illegalities were readily apparent, the district court did not err in its judgment. View "Hammons v. Weber County" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiffs’ complaint against Weber County claiming that the County had violated Utah Code 59-22-103 and 59-2-103.5, which establish the tax exemption for primary residential property.Plaintiffs paid taxes on their primary residence but later learned that the County had not given them the residential exemption. The district court entered a judgment on the pleadings dismissing Plaintiffs’ causes of action, concluding, inter alia, that the assessor acted within the scope of his authority in reclassifying Plaintiffs’ property as “non-primary residential.” In affirming, the Supreme Court held that Plaintiffs’ challenges to the taxes they paid must fall under Utah Code 59-2-1321, which requires taxpayers to point an “error or illegality that is readily apparent from county records.” Because Plaintiffs did not challenge this requirement or show that the alleged errors or illegalities were readily apparent, the district court did not err in its judgment. View "Hammons v. Weber County" on Justia Law

The Supreme Court affirmed the juvenile court’s order terminating J.M.B.’s guardianship and custody of J.B. and denied the guardian ad litem’s (GAL) motion to dismiss this case for lack of jurisdiction.After J.M.B. separated from J.B.’s biological mother, J.M.B. became J.B.’s legal guardian and was also given custody of the child. J.M.B.’s guardianship and custody were subsequently terminated, and the juvenile court determined, after a trial, that J.M.B.’s guardianship rights should be terminated. J.M.B. filed this appeal. During oral arguments, the GAL renewed a motion to dismiss for lack of jurisdiction, arguing that this appeal was moot because J.B.’s adoption had been finalized for more than one year. The Supreme Court held (1) the case was not moot because J.M.B.’s action and appeal satisfied the time constraints set forth in Utah Code 78B-6-133(7)(d); (2) the juvenile court had jurisdiction to vacate the district court’s orders yielding guardianship rights to J.M.B.; (3) J.M.B. waived her statutory right to counsel; and (4) J.M.B. failed to preserve her remaining arguments in the juvenile court proceedings below. View "In re J.B." on Justia Law

The Supreme Court affirmed the district court’s judgment in favor of Defendant on Plaintiff’s medical malpractice claim on the grounds that the Utah Medical Malpractice Act’s two-year statute of limitations barred Plaintiff’s claim. Specifically, the Court held (1) a jury could permissibly find for Defendant based on the evidence before it; (2) the trial court’s decision not to grant summary judgment was not reviewable; (3) the trial court’s evidentiary decisions were not in error; (4) a directed verdict was not warranted where sufficient evidence was offered to sustain the jury verdict in favor of Defendant; and (5) the jury instructions in this case were not misleading. View "Arnold v. Grigsby" on Justia Law

The Supreme Court affirmed the district court’s grant of summary judgment in favor of Defendants, holding that Plaintiffs' claims were either moot or failed to state a claim as a matter of law.The hospital at which an injured child received medical care sought to secure payment for that care by asserting liens against the child’s interest in the tort claim against the driver of the car that struck the child. The child and his mother brought claims against the hospital owner and its payments vendor, arguing that the liens violated Medicaid law. When the liens were released, the district court granted summary judgment in favor of Defendants. The Supreme Court affirmed on the principles of mootness and Plaintiffs’ failure to state a claim as a matter of law. View "Shaffer v. IHC Health Services, Inc." on Justia Law

The court of appeals has the same authority to overturn its own precedent as does the Supreme Court and did not err in this case in concluding that collateral legal consequences will not be presumed when an appeal from a probation revocation has otherwise become moot.While Defendant’s appeal of the revocation of his probation was in process, Defendant completed the sentence required by the revocation and was released. Although two of its prior decisions had contradictory holdings, the court of appeals dismissed Defendant’s case as moot because of his release. The Supreme Court affirmed, holding (1) the court of appeals acted appropriately in overturning its prior precedent in this case; and (2) although collateral legal consequences are presumed to avoid mootness in appeals of criminal convictions, they are not presumed for appeals of probation revocations, and therefore, any defendant wishing to continue a moot appeal of a probation revocation must establish collateral legal consequences. View "State v. Legg" on Justia Law