Justia Utah Supreme Court Opinion Summaries

Attorneys in Utah representing injured workers in workers’ compensation claims receive their fees out of the compensation awarded to the worker. IWA challenged the statute delegating the authority to regulate these fees to the Labor Commission and the Labor Commission's fee schedule. The court held that the regulation of attorney fees is included within the power to govern the practice of law. Because the Utah Supreme Court is vested with exclusive inherent and constitutional authority to govern the practice of law - and the court cannot under the separation-of-powers doctrine delegate the regulation of attorney fees to the legislature or the Commission - the court held the Commission’s fee schedule and its authorizing statute unconstitutional. The court declined to enact a fee schedule regulating the fees of injured workers' attorneys at this time. View "Injured Workers Ass'n of Utah v. State" on Justia Law

USA Power, LLC developed a power plant project in Mona, Utah called the “Spring Canyon vision.” Meanwhile, PacifiCorp entered into negotiations to purchase USA Power’s Spring Canyon assets, and USA Power provided PacifiCorp with details on the entire project. PacifiCorp terminated the negotiations, however, and began construction on a power plant project in Mona that was very similar to the Spring Canyon project. PacifiCorp also retained Jody Williams, USA Power’s former attorney, to help it obtain water rights for its project, called the Currant Creek project. USA Power brought suit against Williams, asserting malpractice claims for Williams’s alleged breach of her fiduciary duties of confidentiality and loyalty, and against PacifiCorp, alleging misappropriation of USA Power’s trade secrets. The trial court granted summary judgment for Defendants. The Supreme Court reversed. On remand, the jury returned a special verdict against PacifiCorp and Williams. The trial court reduced the unjust enrichment award against PacifiCorp, granted Williams’s judgment notwithstanding the verdict motion for lack of evidence related to causation, and determined that USA was entitled to attorney fees. Both parties appealed. The Supreme Court affirmed the trial court’s rulings as to each issue presented on appeal, holding that the court did not err in its judgment. View "USA Power, LLC v. PacifiCorp" on Justia Law

Plaintiff was seriously injured during the course of his employment with Defendant. Plaintiff filed suit alleging that Defendant’s negligence caused his injuries. Defendant moved for summary judgment asserting that it was immune from suit under the exclusive remedy provision of the Utah Workers’ Compensation Act. The district court granted the motion, determining that Defendant qualified for immunity under the “eligible employer” statute. The court of appeals reversed, concluding that Defendant did not “secure the payment” of workers’ compensation benefits for Plaintiff as required by the statute. The Supreme Court reversed, holding that Defendant qualified as an “eligible employer” under the workers’ compensation statutes and fulfilled all of the statutory requirements. View "Nichols v. Jacobsen" on Justia Law

The United States District Court for the District of Utah certified questions of law to the Supreme Court regarding Qualified Political Parties (QPP). The first question asked whether Utah law requires that a QPP permit its members to seek its nomination by either or both of the methods set forth in Utah Code 20A-9-407 and 20A-9-408 or whether a QPP may preclude a member from seeking the party’s nomination by gathering signatures under section 20A-9-408. The second question asked whether the Lieutenant Governor must treat a registered political party (RPP) that has selected to be designated as a QPP as a RPP under Utah law. The Supreme Court answered (1) Utah Code 20A-9-101 requires that QPP party members may choose the method of candidacy qualification; and (2) the certified question regarding the Lieutenant Governor’s obligations is hypothetical and not ripe for decision. View "Utah Republican Party v. Cox" on Justia Law

Plaintiff ClearOne is a Utah corporation and Defendant Revolabs is a competitor incorporated in Delaware with its principal place of business in Massachusetts. The underlying dispute arose when Revolabs recruited and hired Timothy Mackie while he was still employed by ClearOne. ClearOne brought this suit in Utah district court, alleging intentional interference with a contractual relationship, predatory hiring, and aiding and abetting a breach of fiduciary duty. Revolabs filed a motion to dismiss for lack of personal jurisdiction. The trial court granted the motion. The Supreme Court affirmed, holding (1) ClearOne failed to allege that Revolabs had sufficient minimum contacts to subject it to specific personal jurisdiction in Utah; and (2) the trial court did not abuse its discretion in denying discovery to determine whether Revolabs was subject to general personal jurisdiction in Utah. View "ClearOne, Inc. v. Revolabs, Inc." on Justia Law

Plaintiff was babysitting a four-year-old boy when the boy threw a toy at her, striking her in the eye. The impact caused Plaintiff to lose all vision in that eye. Plaintiff sued the boy’s parents for negligent supervision and the boy for negligence. The district court granted summary judgment on the negligent supervision claim against the parents but denied summary judgment on the negligence claim against the boy, concluding that a four-year-old boy can be liable for negligence under Utah law. The Supreme Court reversed, holding that children under the age of five may not be held liable for negligence. View "Nielsen v. Bell" on Justia Law

Plaintiff was babysitting a four-year-old boy when the boy threw a toy at her, striking her in the eye. The impact caused Plaintiff to lose all vision in that eye. Plaintiff sued the boy’s parents for negligent supervision and the boy for negligence. The district court granted summary judgment on the negligent supervision claim against the parents but denied summary judgment on the negligence claim against the boy, concluding that a four-year-old boy can be liable for negligence under Utah law. The Supreme Court reversed, holding that children under the age of five may not be held liable for negligence. View "Nielsen v. Bell" on Justia Law

Salt Lake City Corp. used its power of eminent domain to condemn land owned by Evans Development Group, LLC in order to exchange the property for another piece of property owned by Rocky Mountain Power. The City filed a complaint asserting several public uses and public purposes for the condemnation. Evans moved for summary judgment, arguing that the City lacked statutory authority to condemn its property because the condemnation was not for a public use as required by Utah Code 78B-6-501. The City filed a cross-motion for partial summary judgment as to the issue of public use. The district court granted summary judgment in favor of the City. The Supreme Court reversed, holding that although a property exchange may not be completely prohibited by the relevant eminent domain statutes, it may not be accomplished in the manner attempted in this case. View "Salt Lake City Corp. v. Evans Dev. Group, LLC" on Justia Law

Salt Lake City Corp. used its power of eminent domain to condemn land owned by Evans Development Group, LLC in order to exchange the property for another piece of property owned by Rocky Mountain Power. The City filed a complaint asserting several public uses and public purposes for the condemnation. Evans moved for summary judgment, arguing that the City lacked statutory authority to condemn its property because the condemnation was not for a public use as required by Utah Code 78B-6-501. The City filed a cross-motion for partial summary judgment as to the issue of public use. The district court granted summary judgment in favor of the City. The Supreme Court reversed, holding that although a property exchange may not be completely prohibited by the relevant eminent domain statutes, it may not be accomplished in the manner attempted in this case. View "Salt Lake City Corp. v. Evans Dev. Group, LLC" on Justia Law

In 2002, Appellant was convicted of murder. The Supreme Court affirmed the conviction on appeal. Appellant later filed a petition under Part 3 of the Post-Conviction Remedies Act seeking testing on previously untested items from the murder scene and arguing that the DNA testing would prove his factual innocence. The State subsequently filed a response asking the district court to dismiss Appellant’s petition. Before Appellant had an opportunity to oppose the State’s filing, the district court dismissed Appellant’s petition on the grounds that Appellant failed to establish a non-tactical reason for declining DNA testing at trial. Thereafter, the district court denied Appellant’s motion for reconsideration. The Supreme Court reversed, holding that the district court erred in refusing to allow Defendant an opportunity to file a response to the State’s opposition to his petition under Utah R. Civ. P. 65C. Remanded. View "Gordon v. State" on Justia Law