Justia Utah Supreme Court Opinion Summaries

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

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

The Supreme Court affirmed Defendant’s convictions of possession of drugs and drug paraphernalia, holding that the trial court did not err in denying Defendant’s motion to suppress evidence obtained during a Terry stop. Specifically, the Court held (1) when law enforcement officers stopped Defendant’s vehicle, they had reasonable suspicion to investigate two traffic violations and possible drug possession; (2) when the officers approached the vehicle they gained reasonable suspicion of driving under the influence; and (3) under Terry v. Ohio, 392 U.S. 1 (1968), the officers were entitled to detain Defendant for a reasonable time while they investigated these offenses. View "State v. Binks" on Justia Law

Here, the Supreme Court clarified the standard the Crime Victims Restitution Act (CVRA) requires the district court to employ to determine whether a defendant caused the loss for which a victim seeks restitution.Defendant in this case sexually abused Victim several times and pleaded guilty to two counts of aggravated sexual abuse of a child. Victim intervened in Defendant’s restitution hearing to seek restitution for the anticipated cost of mental health treatment for the remainder of her life. The district court entered orders for complete and court-ordered restitution. On appeal, Defendant argued that Victim’s damages were caused, in part, by her subsequent sexual abuse by another person and that the court based its complete restitution award upon speculation about expenses Victim would incur in the future. The Supreme Court remanded the case, holding that the CVRA requires that a district court include the losses that a defendant proximately causes in its complete restitution determination. Remanded with directions that the district court ensure that it rests its restitution calculation on non-speculative evidence of losses that Victim has incurred or will likely incur. View "State v. Ogden" on Justia Law

The court of appeals did not err in concluding that the denial of Robert Oltmanns’ insurance claim by his insurer, Fire Insurance Exchange, was “fairly debatable,” thus negating Oltmanns’ demand for attorney fees and expenses for a coverage dispute and appeal.When Oltmanns was named as a defendant in a personal injury case he filed a claim with Fire Insurance. Fire Insurance brought a declaratory judgment action to determine whether the claim was covered under Oltmanns’ policy. The court of appeals ruled that the claim was covered. Oltmanns, in turn, filed a counterclaim seeking attorney fees for the declaratory judgment action on the grounds that it was brought in bad faith. The district court granted summary judgment for Fire Insurance, finding that the insurer’s actions were reasonable because the coverage issue was “fairly debatable.” The court of appeals affirmed. The Supreme Court affirmed, holding that the coverage question was, indeed, fairly debatable. View "Fire Insurance Exchange v. Oltmanns" on Justia Law