Justia Utah Supreme Court Opinion Summaries

Defendant entered a conditional guilty plea to one count of assault by a prisoner. Defendant appealed, arguing (1) the district court erred in denying her motion to dismiss because a video recording of the assault was lost or destroyed by the State, and this loss of evidence violated her due process rights; and (2) the district court applied the wrong legal standard to her claim by imposing a threshold requirement that she demonstrate a reasonable probability that the evidence would have been exculpatory. The Supreme Court reversed, holding (1) the district court correctly recognized that the due process analysis set forth in State v. Tiedemann encompasses a threshold reasonable probability requirement; (2) the court erred by applying an overly stringent interpretation of what constitutes a “reasonable probability” and in ruling that Defendant failed to satisfy the threshold requirement; (3) the court erred in its application of the factors set forth in Tiedemann; and (4) dismissal was the appropriate remedy for the negligence of the State in failing to preserve the footage and the crucial role that footage would have played in this case. View "State v. DeJesus" on Justia Law

Defendant was charged with the alleged rape or object rape of four women. During Defendant’s trial for the rape of K.S., the State moved to introduce the testimony of the other women, including A.P., under Utah R. Evid. 404(b) and the doctrine of chances. The district court granted the motion. Thereafter, Defendant entered a conditional guilty plea to the rapes of two of the four women. The court of appeals reversed in part, concluding (1) State v. Verde’s four foundational requirements displaced the factors set forth in State v. Shickles for purposes of a Utah R. Evid. 403 balancing test; and (2) the district court erred in its decision to admit the testimony of A.P. The Supreme Court affirmed but under different reasoning, holding (1) in applying Rule 403, a court is bound by the language of the rule but is not required to consider any set of elements or factors; and (2) the district court in this case did not abuse its discretion in failing to consider the Verde requirements but did abuse its discretion by mechanically applying the Shickles factors to assess the probative value of the State’s Rule 404(b) evidence. View "State v. Lowther" on Justia Law

The mandatory joinder statute, Utah Code 76-1-401, prohibits the State from prosecuting a defendant in separate actions for conduct that may establish separate offenses under a “single criminal episode.” A “single criminal episode” is defined as “all conduct which is closely related in time and is incident to an attempt or an accomplishment of a single criminal objective.” Petitioner filed a motion to dismiss the wage crimes prosecution as barred by the mandatory joinder statute, arguing that the State violated section 76-1-401 by prosecuting him from 2011 to 2012 for wage crimes after having prosecuted and convicted him in 2009 and 2010 for tax crimes. Petitioner argued that the conduct underlying both prosecutions was part of a single criminal episode because it was closely related in time and incident to an attempt of accomplishment of the single criminal objective of misappropriation of money in his business setting. The district court denied the motion, and the court of appeals affirmed. The Supreme Court affirmed, holding that Defendant’s conduct did not have a single criminal objective and thus did not constitute a single criminal episode. View "State v. Rushton" on Justia Law

This case involved a claim for restitution by the victim of a sex crime committed by Defendant. The State alleged that Defendant’s crimes led to the victim’s depression, which impacted her ability to work and required counseling. The district court ordered Defendant to pay $12,934 in lost income in addition to restitution of the costs of the victim’s counseling. On appeal, Defendant challenged the lost income award, arguing that lost income is not available under the Crime Victims Restitution Act unless “the offense resulted in bodily injury to a victim.” The court of appeals affirmed. The Supreme Court reversed, holding that restitution for lost income was not available in this case because there was no allegation that Defendant’s offense “resulted in bodily injury” to the victim. View "State v. Wadsworth" on Justia Law

Defendant was charged and tried on four counts of theft and one count of attempted theft. After a jury trial, all jurors found Defendant guilty on all five counts. Defendant challenged his conviction under the Unanimous Verdict Clause of the Utah Constitution, alleging that there was lack of unanimity as to alternative factual theories advanced by the prosecution in support of some of the theft counts against him. Alternatively, Defendant alleged two other sets of trial errors as grounds for reversal. The Supreme Court affirmed, holding (1) precedent does not support the requirement of unanimity or sufficiency of the evidence for alternative, exemplary means of committing a crime, and the Utah Constitution imposes no such requirement; (2) the evidence was sufficient to support the jury’s verdict; and (3) Defendant otherwise failed to identify a basis for reversal of his convictions. View "State v. Hummel" on Justia Law

The administrator of the Utah Motor Vehicle Enforcement Division denied Tesla Motors UT, Inc., a wholly owned subsidiary of a motor vehicle manufacturer, an application for a license to sell new motor vehicles, determining that the application implicated both the Motor Vehicle Business Regulation Act (Licensing Act) and the New Automobile Franchise Act (Franchise Act). The Tax Commission affirmed. The Supreme Court affirmed, holding that the Licensing Act and Franchise Act together prohibit a wholly owned subsidiary of a motor vehicle manufacturer from obtaining a license to sell the manufacturer’s new motor vehicles in stores in Utah, and the statutory scheme is constitutional. View "Tesla Motors UT, Inc. v. Utah Tax Commission" on Justia Law

At issue in this appeal was the scope of the “covered profession” clause of a professional liability errors and omissions insurance policy issued to Utah County Real Estate, LLC (Prudential) by Houston Casualty Company. While working as a real estate agent for Prudential, Robert Seegmiller engaged in a professional relationship with the plaintiffs in this action (collectively, Investors) on a real estate deal that went sour. The Investors obtained a judgment against Seegmiller for negligence. Rather than execute the judgment against Seegmiller, the Investors settled with him, acquiring any claims he might have against Prudential’s insurer, Houston Casualty. The Investors then brought this action alleging that Houston Casualty breached the policy by failing to defend and indemnify Seegmiller. The district court granted summary judgment for Houston Casualty. The Supreme Court affirmed on the ground that Seegmiller’s conduct in the transaction was not covered by the policy because he was not providing services “for a fee” in the transaction. View "Compton v. Houston Casualty Co." on Justia Law

At dispute in this case was a mining road built on Flagstaff Mountain over a century ago. Stichting Mayflower Mountain Fonds and Stichting Mayflower Recreation Fonds (collectively, Mayflower) asserted a right to use the road as a public highway and under a common law prescriptive easement claim. Mayflower later moved to amend its complaint seeking to add an appurtenant easement claim. The district court granted summary judgment for Defendants, dismissed Mayflower’s public road and prescriptive easement claims, and denied Mayflower’s motion for leave to file a second amended complaint. The Supreme Court affirmed, holding (1) Mayflower’s public roads claim failed because Mayflower did not establish a genuine issue of material fact on the public use necessary to show that the road had become a public road; (2) the common law prescriptive easement claim failed because the evidence and arguments presented by Mayflower on appeal were never presented to the district court in the proceedings below; and (3) the district court did not abuse its discretion in denying Mayflower’s motion for leave to file a second amended complaint. View "Stichting Mayflower Mountain Fonds v. United Park City Mines Co." on Justia Law

Friends of Great Salt Lake (Friends) challenged the decision of the Division of Forestry, Fire and State Lands (Division) granting a mining lease covering a small portion of the Great Salt Lake. Friends made three simultaneous attempts to halt the lease in requests and petitions submitted to the Division or to the Utah Department of Natural Resources (Department). The Division and Department issued a single agency order denying all three. Friends appealed and sought leave to amend its complaint to raise additional constitutional and statutory arguments. The district court affirmed the rejection of Friends’ requests and petitions, denied in part Friends’ attempt to amend its complaint, and subsequently dismissed Friends’ remaining arguments on summary judgment. Friends appealed and, alternatively, sought extraordinary relief. The Supreme Court (1) affirmed in large part and denied Friends’ request for extraordinary relief; and (2) reversed to a limited extent, holding that the Division was required to engage in “site-specific planning” under the applicable provisions of the Utah Administrative Code. Remanded to allow the Department to decide on the appropriate remedy for the failure to perform such planning. View "Friends of Great Salt Lake v. Utah Department of Natural Resources" on Justia Law

In 1997, Paul Haik argued before the federal district court that Salt Lake City and Alta’s refusal to extend adequate municipal water services to his undeveloped land in the Albion Basin Subdivision was a violation of equal protection and amounted to an unconstitutional taking. The federal court ruled against Haik. In 2012, Haik filed another federal lawsuit alleging different legal claims but, for the most part, the same facts. In the lawsuit, Haik again sought a determination that Salt Lake City was required to supply him with enough water to develop his property in Albion Basin. The federal court again ruled against Haik. Thereafter, Salt Lake City sued Haik in state court seeking, inter alia, to adjudicate Haik’s and others’ interests in water rights in Little Cottonwood Creek. Haik counterclaimed, adducing exactly the same facts as he put before the federal district court in 2012. The district court dismissed the counterclaims on the grounds that they were barred by the doctrine of res judicata. Although Haik did not raise each and every claim in the federal court that he sought to raise here, the Supreme Court affirmed, holding that, on the operative facts before the Court, it was impossible for Haik to overcome the hurdle of claim preclusion. View "Salt Lake City Corp. v. Haik" on Justia Law