Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed the district court’s dismissal of Homebuyer's construction defect claims against the Contractor that built his home on the ground that Homebuyer was not in privity with Contractor and had no right to sue as an assignee.Property Owner entered into an agreement with Contractor to build a house on the property and then assigned its rights to the home and the construction agreement to Company. Company then sold the home to Homebuyer but did not assign its interest in the construction agreement to Homebuyer. After discovering several purported construction defects, Homebuyer sued Contractor for breach of the construction agreement and breach of warranty. Homeowner was subsequently assigned Company’s interest in claims Company may assert against Contractor. The district court granted summary judgment to Contractor. The Supreme Court affirmed, holding that Homebuyer had no right to sue under Utah Code 78B-4-513 because he did not acquire a right to sue for breach of contract or warranty as an assignee - either at the time he purchased the home or at the time of the assignment. View "Tomlinson v. Douglas Knight Construction, Inc." on Justia Law

In August 2007, Lisa Penunuri was injured when she fell off her horse during a guided horseback trail ride at Sundance Resort. She and her husband sued for negligence and gross negligence against Rocky Mountain Outfitters, L.C. (the company that provided the trail guide services) as well as various defendants associated with the resort (collectively, Sundance). In 2013, the Utah Supreme Court affirmed the dismissal of Ms. Penunuri’s ordinary negligence claims, leaving only her claims for gross negligence. The district court granted summary judgment in favor of Sundance on the gross negligence claims and awarded Sundance its costs, including certain deposition costs. Penunuri appealed, and the appellate court affirmed. The Supreme Court granted certiorari on three questions: (1) whether the court of appeals erred in concluding that summary judgment may be granted on a gross negligence claim even though the standard of care is not "fixed by law;" (2) whether the court of appeals erred in affirming the district court’s conclusion that reasonable minds could only conclude there was no gross negligence under the circumstances of this case; and (3) whether the court of appeals erred in affirming the district court’s award of deposition costs to Sundance. Finding no reversible error on any of those claims, the Supreme Court affirmed the court of appeals on each issue. View "Penunuri v. Sundance Partners" on Justia Law

The court of appeals vacated Defendant’s conviction, rendered after a jury trial, of attempted murder but affirmed Defendant’s conviction of possession of a firearm by a restricted person. The court found that Defendant’s counsel provided ineffective assistance when he failed to object to a defective jury instruction on the lesser-included offense of attempted manslaughter, and the error prejudiced Defendant’s trial. The Supreme Court reversed the court of appeals with respect to the jury instruction issue, holding that the court of appeals erroneously failed to perform fully the prejudice analysis required by Strickland v. Washington, 466 U.S. 668 (1984), and that Defendant was not prejudiced by his counsel’s complicity in the jury receiving a flawed instruction. View "State v. Garcia" on Justia Law

In 2003, a corporation was assigned a lease that permitted a restaurant to operate. Xiao-Yan Cao, the corporation’s president, personally guaranteed the corporation’s performance. In 2006, the lease was assigned to Hong Lin. As part of the assignment, the lease term was extended until 2013. Both Cao and Lin signed the lease extension as guarantors. In 2010, Lin stopped making timely rent payments. Lin and the property’s landlord agreed to a repayment schedule to permit Lin to catch up. In 2013, Lin defaulted on rent payments. The landlord sued both Lin and Cao for a sum representing the last month’s rent and a balance from the month prior. The district court concluded that the 2010 repayment materially modified the contract and discharged Cao’s guaranty. The court of appeals reversed, concluding that extending the period within which a tenant could pay its rent did not materially modify the contract. The Supreme Court affirmed, holding that the court of appeals correctly determined that the 2010 repayment agreement did not materially modify the contract and that Cao was not relieved of her responsibilities as guarantor. View "PC Riverview, LLC v. Cao" on Justia Law

A credit card error that caused Carole and James Marziale’s complaint against Spanish Fork City to be rejected did not affect the timeliness of the Marziales’ filing.The Marziales submitted a personal injury complaint with an undertaking in the Provo division of the Fourth Judicial District against the City. The status history showed that a clerk manually rejected the filing due to a credit card error. After the statute of limitation for their claim expired, the Marziales’ learned that their filings had been rejected. They refiled the complaint and undertaking in the Provo division, and it was accepted with proper payment. The City filed a motion for summary judgment, arguing that the court lacked jurisdiction over the action because the filing date was outside of the statute of limitations. The court granted the motion. The court of appeals reversed. The Supreme Court reversed, holding that the Marziales’ credit card payment error did not affect the validity of the filing of their complaint or undertaking under Utah R. Civ. P. 3, and therefore, the Marziales’ filings were timely filed. View "Marziale v. Spanish Fork City" on Justia Law

The weekend before Defendant’s trial, Defendant and the State entered into a plea agreement. Before Defendant entered his plea, however, the State rescinded its offer because Defendant’s alleged victim disapproved of the agreement. At Defendant’s request, the court granted a continuance and rescheduled the jury trial. Defendant subsequently filed a motion to enforce the plea agreement, asserting that he had detrimentally relied on the State’s offer. The district court rejected the motion, and Defendant sought interlocutory review. The Supreme Court affirmed the district court’s order denying enforcement of the plea agreement, holding (1) the State may withdraw from a plea bargain agreement at any time prior to the actual entry of a defendant’s guilty plea or other action by a defendant constituting detrimental reliance on the agreement; and (2) Defendant did not perform under the terms of the plea agreement before the State rescinded its offer and failed to show that he detrimentally relied on the State’s offer. View "State v. Francis" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the conviction of Defendant for the murder of his wife. During trial, Defendant sought to reduce the conviction from murder to manslaughter by establishing special mitigation through extreme emotional distress. The jury rejected Defendant’s arguments for special mitigations. On appeal, Defendant argued that the jury instructions concerning extreme emotional distress were in error. The court of appeals affirmed. The Supreme Court agreed, holding (1) a criminal defendant who seeks to establish special mitigation by extreme emotional distress must prove that his loss of self-control is reasonable; and (2) under the circumstances of this case, the jury instructions accurately described the law. View "State v. Lambdin" on Justia Law

The Supreme Court affirmed the district court’s grant of partial summary judgment in favor of Hadley Christensen, who claimed reimbursement pursuant to Utah Code 52-6-201 from Juab School District, his former employer, for attorney fees and costs incurred in a successful defense against charges of aggravated sexual abuse of a child. The district court awarded judgment pursuant to a stipulation entered by the parties. The Supreme Court held (1) the reimbursement statute provides reimbursement for the successful defense against an information filed in connection with the acts of a public officer or employee; (2) under the reimbursement statute, Christensen was entitled to reimbursement; and (3) Christensen was charged under color of authority as a person in a position of special trust, a prong in the reimbursement statute. View "Christensen v. Juab School District" on Justia Law

The Supreme Court reversed the district court’s denial of the motion to dismiss the lawsuit brought by several property developers (Developers) alleging that the City of West Jordan violated statutory provisions that regulate how a municipality may spend impact fees collected from developers. The court held (1) Developers had standing to challenge the constitutionality of the impact fees they were assessed; (2) Developers failed to state a takings claim for which relief can be granted because Developers’ allegations that West Jordan either failed to spend impact fees within six years or spent the fees on impermissible expenditures were inadequate to support a constitutional takings claim; and (3) Developers did not have standing to bring a claim in equity. View "Alpine Homes, Inc. v. City of West Jordan" on Justia Law

The juvenile court erred in using a per se rule that “[h]itting a child with a belt or strap or another object is abuse” because the rule is overbroad and alters the statutory meaning of “abuse” within the meaning of the Utah Code.This case involved four children. Mother was the mother of all four children, and Father was the biological father of the younger two. The State filed a petition seeking to adjudicate the children as abused and neglected under Utah Code 78A-6-105. The parties stipulated to a number of findings of fact. The juvenile court determined that Parents abused the children under section 78A-6-105. Parents appealed, arguing that the juvenile court erred when it concluded that spanking a child with a belt, without any additional proof of harm, constitutes abuse within the meaning of Utah law. The Supreme Court agreed, holding that the stipulated facts did not support an abuse determination. View "In re K.T." on Justia Law