Justia Utah Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of aggravated murder, obstructing justice, and five counts of discharging a firearm from a vehicle. On appeal, Defendant asked that his convictions be set aside based on an insufficiency of the evidence because a trio of witnesses changed their testimony after receiving deals from the State, and therefore, the testimony they each offered at trial was inherently dubious to the point that no reasonable jury could have relied on it to convict him. The Supreme Court affirmed, holding (1) the inconsistencies between the three witness’s pretrial statements and in-court testimony did not render their testimony apparently false; (2) moreover, ample additional evidence supported each of Defendant’s convictions; and (3) therefore, the trial court did not err, let alone plainly err, when it submitted Defendant’s case to the jury. View "State v. Prater" on Justia Law

Shayne Crapo defaulted on a $250,000 loan from Zions First National Bank. After the expiration of a three-year period with no payments being made on the loan, Zions Bank issued Mr. Crapo a Form 1099-C - a reporting tool designed to help the IRS track lenders’ debt forgiveness. Crapo claimed that he reported the $250,000 as income on his tax return, thus increasing his tax burden for that year. After Zions Bank brought a deficiency action to recover the amount due on the loan, Crapo argued that the Form 1099-C was prima facie evidence that Zions Bank discharged the debt and that Zions Bank was estopped from collecting the debt. The district court rejected Crapo’s arguments and granted summary judgment in favor of Zions Bank. The Supreme Court affirmed, holding that Crapo failed to show that there was a genuine dispute of material fact as to either actual discharge or estoppel. View "Crapo v. Zions First National Bank" on Justia Law

Defendant was convicted of multiple counts of rape, sodomy, and sexual abuse of a twelve-year-old victim. The court of appeals reversed, concluding that the district court erred in admitting evidence of Defendant’s past misconduct. Specifically, the court held that the district court erred in failing to perform a “scrupulous examination” of the character evidence introduced by the State. The Supreme Court reversed the court of appeals and reinstated the judgment of conviction, holding (1) language in this Court’s prior opinions that speaks of “scrupulous examination” of character evidence under Utah R. Evid. 404(b) is hereby repudiated; (2) the district court properly admitted the character evidence at issue in this case; and (3) the district court properly refused to allow Defendant to present evidence of the victim’s sexual experience under Utah R. Evid. 412 and the Sixth Amendment. View "State v. Thornton" on Justia Law

Debra Jarvis was driving a bus owned by Lake Shore Motor Coach Lines, Inc. when she experienced a sudden and unforeseeable loss of consciousness. Her loss of consciousness caused the bus to roll over, injuring several passengers. Some of the injured passengers filed separate lawsuits in a Utah court seeking damages. Two of the plaintiffs moved for partial summary judgment, asserting that Lancer Insurance Co., Lake Shore’s insurer, was strictly liable for the passengers’ injuries under Utah Code 31A-22-303(1). The motions were denied. Lancer Insurance filed a separate federal case seeking a declaratory judgment confirming the state district court’s interpretation of Utah Code section 31A-22-303(1), thus reinforcing the conclusion that this provision preserves the common-law “sudden incapacity” defense and requires proof of fault to sustain liability. The federal district court certified two questions to the Supreme Court regarding the proper interpretation of section 31A-22-303(1). The Supreme Court answered (1) section 31A-22-303(1) overrules the common-law doctrine of sudden incapacity in a manner imposing strict liability on a driver (and her insurer); and (2) a driver (and her insurer) is subject to liability only up to the amount of the insurance coverage available under an applicable policy. View "Lancer Insurance Co. v. Lake Shore Motor Coach Lines, Inc." on Justia Law

Natalie Heslop overdosed on prescription drugs. The next day, Natalie rolled her truck down an embankment. Natalie informed the responding police officer, medical personnel, her family, and an insurance adjuster that the accident had been a suicide attempt. Natalie’s insurance policy provided that it would exclude coverage to any injured person “if the person’s conduct contributed to his injury…by intentionally causing injury to himself.” Natalie and her husband, Brandon Heslop, attempted to collect from Bear River Mutual Insurance Company under both a personal injury protection claim for Natalie’s personal injuries and a property damage claim for damage to the truck. Bear River denied the claims based on Natalie's admission that she intended to drive down the embankment. The Heslops subsequently filed a complaint against Bear River. The district court granted summary judgment to Bear River as to both the personal injury claim and the property damage claim. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment on the Heslops’ claims. View "Heslop v. Bear River Mutual Insurance Co." on Justia Law