Justia Utah Supreme Court Opinion Summaries

Residents of Orem City and Provo City (collectively, Petitioners) sought to have a referendum placed on the November 2017 ballot. Both Orem City and Provo City refused, concluding that the resolutions could not be referred to the voters as a matter of law. Petitioners sought an extraordinary writ ordering that the referenda be placed on the ballot and filed their petitions in accordance with Utah Code 20A-7-607(4)(a). The Supreme Court denied the petitions without prejudice, holding that Petitioners failed to carry their burden of establishing under Utah R. App. P. 19(b)(4)-(5) that it would be impractical or inappropriate for them to file their petitions in the district court. View "Anderson v. Provo City" on Justia Law

Barbara Bagley and Vom Baur, her common law husband, were traveling in a Range Rover when Bagley lost control of the vehicle and flipped it. Ten days later, Baur died from the injuries he sustained in the accident. Bagley, in her capacity as sole heir and personal representative of her deceased husband’s estate, brought suit against herself as an individual, alleging that she negligently caused her husband’s death. Bagley, who sued under Utah’s wrongful death and survival action statutes, brought suit to compel State Farm Insurance Company, with whom she maintained a motor vehicle insurance policy, to indemnify her. The district court dismissed the complaint, concluded that a person cannot simultaneously act as plaintiff and defendant in a wrongful death or survival action suit. The court of appeals reversed. The Supreme Court affirmed, holding that the court of appeals did not err when it concluded that the wrongful death and survival action statutes permit a person acting in the legal capacity of an heir or personal representative to sue herself in an individual capacity for negligently causing a decedent’s death or injury. View "Bagley v. Bagley" on Justia Law

At issue in this case was the Director of the Utah Division of Air Quality’s (UDAQ) approval of certain changes at Tesoro Refining and Marketing Company’s Salt Lake City Refinery. Utah Physicians for a Healthy Environment and the Utah Chapter of the Sierra Club (collectively, Petitioner) filed a request for agency action challenging the permit allowing the changes at the refinery, arguing that the Director of UDAQ conducted a legally insufficient analysis by approving Tesoro’s changes. Upon completion of permit review adjudicative proceedings, an Administrative Law Judge (ALJ) recommended that Petitioners’ challenge be dismissed. The Executive Director of the Utah Department of Environmental Quality adopted the ALJ’s findings of fact, conclusions of law, and proposed disposition and dismissed each of Petitioners’ arguments. The Supreme Court dismissed Petitioners’ appeal, holding that because Petitioners did not address alleged deficiencies in the Executive Director’s final order in their opening brief, they failed to meet their burden of persuasion on appeal. View "Utah Physicians for a Health Environment v. Executive Director of Utah Department of Environmental Quality" on Justia Law

In 1910, the district court issued the Little Cottonwood Morse Decree establishing water rights for the Little Cottonwood Creek. In 2013, parties bound by the contractual provisions contained in the Morse Decree filed a postjudgment motion in the case that resulted in the decree asking the district court to modify the decree. The district court denied the motion, concluding that it lacked the authority to reopen the century-old case to modify the final judgment. The Supreme Court affirmed, holding that a postjudgment motion was an inappropriate procedural vehicle to modify the Morse Decree. View "Little Cottonwood Tanner Ditch Co. v. Sandy City" on Justia Law

Suspecting that his ex-girlfriend was planning to steal a motor home, Defendant snatched his ex-girlfriend’s purse to deliver the evidence to the police. Defendant’s conduct led to a fight between him and his ex-girlfriend. The State charged Defendant with aggravated robbery, among other crimes. After a jury trial, Defendant was found guilty. The Supreme Court affirmed, holding (1) the trial court did not err when it declined to reduce Defendant’s conviction from aggravated robbery to robbery; and (2) the trial court did not abuse its discretion in not granting a continuance to permit Defendant to subpoena additional defense witnesses. View "State v. Mackin" on Justia Law

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