Justia Utah Supreme Court Opinion Summaries

Layton City charged Defendant with driving under the influence, driving on a denied license, and leaving the scene of a property-damage accident. Defendant filed a motion to suppress the evidence discovered after police officers investigating a hit-and-run accident entered a private residence with neither permission nor a warrant. The district court granted the motion, concluding that, even though the officers were in the process of obtaining a search warrant at the time they entered the house, the inevitable-discovery exception to the exclusionary rule did not apply in this case. The court of appeals reversed, concluding that the City established the applicability of the inevitable-discovery exception to the warrantless search. The Supreme Court reversed the decision of the court of appeals and affirmed the district court’s order granting Defendant’s suppression motion, holding that the district court correctly determined that the City’s evidence was too speculative to establish inevitable discovery, and therefore, the City failed to meet its burden of establishing the inevitable-discovery exception. View "Brierley v. Layton City" on Justia Law

After a jury trial, Petitioner was convicted of aggravated murder, possession of a dangerous weapon by restricted person, and obstruction of justice. Brandon Wright, one of the State’s witnesses at trial, testified that Petitioner admitted to the aggravated murder when they were both serving prison time. While Petitioner’s appeal was pending, Wright confessed to an unrelated twenty-year-old murder. Based on Wright’s confession, Petitioner petitioned for extraordinary relief, asserting that unless the Court exercises its authority to issue an extraordinary writ, he will be unable to seek a new trial based on this newly discovered evidence until after he has exhausted his direct appeal. The Supreme Court declined to exercise its discretion to grant Petitioner’s petition for extraordinary relief because Petitioner failed to carry his burden of showing that the newly discovered impeachment evidence in this case justifies the Court issuing an extraordinary writ. View "Logue v. Court of Appeals" on Justia Law

This putative class action was filed by a group of property owners who paid certain impact fees imposed by the Washington County Water Conservancy District (District) within a specific time period. Plaintiffs challenged the legality of the impact fees, arguing that the fees were in violation of the Impact Fees Act and amounted to a taking under the state and federal constitutions. The district court granted partial summary judgment in favor of the District and then, pursuant to a stipulation of the parties, certified the case for an immediate appeal under Utah R. Civ. P. 54(b). The Supreme Court dismissed on jurisdictional grounds, holding (1) the case was not properly certified under Rule 54(b); and (2) the Court declines to exercise its discretion to grant interlocutory review. Remanded. View "Washington Townhomes, LLC v. Washington County Water Conservancy Dist." on Justia Law

Twelve years ago, Plaintiff filed a lawsuit against Defendants. The district court eventually dismissed the case for failure to prosecute but did not indicate whether the case was dismissed without prejudice or pursuant to Utah R. Civ. P. 41(b). Thereafter, Plaintiff filed a new action asserting the same claims against the same defendants. Defendants filed a motion to dismiss, arguing that the dismissal operated as a dismissal with prejudice under Rule 41(b). The district court denied the motion to dismiss, finding that the decision in Panos v. Smith’s Food & Drug Centers, Inc. was controlling. In Panos, the court of appeals held that when a judge dismisses a case for failure to prosecute but fails to explicitly provide that the case is dismissed with prejudice or pursuant to Rule 41(b), the presumption is that the case is dismissed without prejudice. The Supreme Court overruled Panos and held (1) the plain text of Rule 41(b) is clear that the presumption of prejudice applies broadly in most cases; (2) in this case, in the absence of a showing that he relied on Panos, Plaintiff was not entitled to a prospective-application of the ruling; and (3) this case should have been dismissed with prejudice. View "Cannon v. Holmes" on Justia Law

In 2005, Connor Libby and Elena Chapa (collectively, Defendants) signed credit card agreements with Federated Capital Corporation’s predecessor-in-interest, a Utah corporation with its principal place of business in Pennsylvania. The agreements contained a forum selection clause and choice of law provision that adopted Utah substantive and procedural law to govern any dispute under the contract. The agreements required Defendants to make monthly payments to the address specific on their billings statements, and each billing statement required Defendants to send their payments to an address in Philadelphia, Pennsylvania. Defendants defaulted in 2006. In 2012, Federated filed separate claims in separate proceedings against Defendants. In each proceeding, the district court granted summary judgment in favor of Defendants, ruling that Utah’s borrowing statute required the court to apply Pennsylvania’s four-year statute of limitations, thereby barring Federated’s claims. Federated appealed, arguing that the agreement’s forum selection clause precluded the application of Utah’s borrowing statute. The Supreme Court affirmed, holding that the borrowing statute applied to and barred Federated’s causes of action. View "Federated Capital Corp. v. Libby" on Justia Law

Rufus Call Willey, the founder of R.C. Willey & Son, died in 1954. The day before he died, he signed a last will and testament. In 2011, two of the decedent’s grandchildren, Helen Immelt and Don McBroom, filed a complaint against their grandmother; their uncle, his brother, and his attorney; and a bank. Plaintiffs alleged that Defendants had deprived Plaintiffs of their rightful inheritance under the terms of the decedent’s will. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding (1) all of Immelt’s claims and most of Broom’s claims were barred by the terms of a 1973 agreement; and (2) McBroom’s breach of fiduciary duty claims were circular and barred by the applicable statute of limitations. View "McBroom v. Child" on Justia Law

Plaintiff filed an action seeking to establish his paternity in and custody over a child he believed to be his son (Child). Both Plaintiff and Mother were residents of Colorado. Mother travelled to Utah two days before Child’s birth and gave birth to Child in Utah. Mother then relinquished Child to a Utah-based adoption agency. For reasons unrelated to this appeal, the district court dismissed the case, but the Supreme Court reversed and remanded. After remand, Adoptive Couple intervened in Plaintiff’s action to request that his suit be dismissed, arguing that the district court lacked subject matter jurisdiction under the Utah Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA). The district court granted the motion to dismiss, concluding that Utah was not Child’s home state for purposes of the UCCJEA. The Supreme Court affirmed, holding that the district court did not err by dismissing Plaintiff’s case on the basis that it lacked jurisdiction under the UCCJEA. View "Nevares v. Adoptive Couple" on Justia Law

Plaintiffs filed a tort suit against Provo City under the Governmental Immunity Act. The complaint was dismissed because Plaintiffs failed to submit an undertaking or bond as required by the statute. Plaintiffs filed a second complaint, this time with the bond required by statute, but by the time the case was refiled, it was untimely under the Act. Provo City moved to dismiss. In response, Plaintiffs pointed to the Savings Statute, a provision outside the Governmental Immunity Act that generally extends the statute of limitations for plaintiffs when a complaint is dismissed other than on the merits. The district court granted the motion to dismiss. The court of appeals reversed, concluding that the Act was complementary to other laws like the Savings Statute, and thus the Savings Statue was applicable. The Supreme Court reversed, holding that the Act forecloses the applicability of the Savings Statute. View "Craig v. Provo City" on Justia Law

A 14-year-old student at Juan Diego Catholic High School suffered serious and life-threatening injuries while using a lift to replace light bulbs in the auditorium, during his drama class. The lift tipped over as students pushed it from one light fixture to another, causing him to suffer life-threatening injuries, including traumatic brain injury. His parents filed a lawsuit, individually and as parents and guardians of the student, claiming negligence and vicarious liability, and seeking to bring a personal claim for loss of filial consortium. The district court dismissed the loss of filial consortium claim and certified the dismissal as final. The Utah Supreme Court vacated, adopting a cause of action for loss of filial consortium to allow parents to recover for loss of filial consortium due to tortious injury to a minor child in cases where the injury meets the definition set forth in Utah Code section 30-2-11, the spousal consortium statute. The court concluded that such a cause of action is not legislatively preempted. View "Benda v. Catholic Diocese of Salt Lake City" on Justia Law

Alan Peterson, the former president of The Layton Companies, Inc. and Layton Construction Co. (Layton), had a falling out with Layton management and later founded SIRQ, a competing construction company. Alleging that Layton exhibited a malicious, wrongful intent in its interactions with SIRQ and Peterson (collectively, Plaintiffs), Plaintiffs sued Layton for intentional interference with economic relations and “false light” invasion of privacy. The jury returned a verdict in favor of Plaintiffs on the intentional interference and false light claims. While this case was pending on appeal, the Supreme Court revised the common law of intentional interference with economic relations. The Supreme Court (1) reversed and remanded for a new trial on the tortious interference claim, holding that parties to cases pending on appeal are entitled to the benefit of an alteration of the common law; and (2) reversed and remanded on the “false light” invasion of privacy claim, holding that the trial judge in this case failed to fulfill the gatekeeping role of assuring that the jury considers only statements that are capable of defamatory meaning. View "SIRQ, Inc. v. Layton Companies, Inc." on Justia Law