Justia Utah Supreme Court Opinion Summaries

Defendant worked for Plaintiff, a technology company, as an engineer. During and after her employment with Plaintiff, Defendant forwarded confidential emails to her private Gmail account, copied a confidential business plan to a thumb drive, and placed protected information on the record in an administrative proceeding. Plaintiff filed suit, alleging that Defendant had violated a non-disclosure agreement and misappropriated company trade secrets. The district court granted summary judgment for Defendant, determining that Plaintiff had failed to make an adequate showing of harm. The court further entered Utah R. Civ. P. 11 sanctions against Plaintiff and awarded attorney fees to Defendant. The Supreme Court reversed, holding (1) there was sufficient evidence of threatened harm - or at least genuine issues of material fact concerning such harm - to defeat Plaintiff’s motion for summary judgment; and (2) because Plaintiff prevailed on Defendant’s motion for summary judgment, Defendant could not be entitled to sanctions or fees. View "Innosys v. Mercer" on Justia Law

Plaintiff filed a public records request under the Government Records Access and Management Act (GRAMA) seeking bank records the State had legally seized during a criminal investigation. The district court denied the request, concluding that article I, section 14 of the Utah Constitution provides a broad right of privacy that prevented the State from disclosing the records. The district court also denied Plaintiff access to a summary of the bank records (the Quicken Summary) and an investigator’s handwritten notes (the Post-it Note), concluding that both documents were protected attorney work product. The Supreme Court reversed, holding (1) there can be no violation of section 14 when the government obtains information through a valid warrant or subpoena, and therefore, the bank records were not exempted from GRAMA’s public disclosure requirements; and (2) the district court correctly classified the Quicken Summary and the Post-it Note as attorney work product, but, because the State terminated its investigation years ago, the interests favoring protection were not as compelling as those favoring disclosure. View "Schroeder v. Utah Attorney General’s Office" on Justia Law

Steven Brown suffered a back injury while working as a school bus driver for the Washington County School District. Brown received workers’ compensation for this injury. In 2007, Brown was reinjured while attending a local festival. The School District denied workers’ compensation liability. An administrative law judge with the Labor Commission concluded that the prior industrial injury was a contributing cause to the second injury and awarded benefits. The Commission and court of appeals affirmed. After clarifying the causation standard under the direct and natural results test for interpreting the Workers’ Compensation Act, the Supreme Court remanded the case back to the Commission to determine whether Brown’s injury met this standard. View "Washington County Sch. Dist. v. Labor Comm'n" on Justia Law

The State sought and received an order freezing more than $3 million of Frank and Joan Steed’s assets under Utah’s Asset Preservation Statute. The State subsequently filed criminal charges against the Steeds and sought a freeze order to ensure adequate funds would be available for the anticipated restitution award. The district court upheld the freeze order. Thereafter, the Steeds were convicted of three counts of failure to file tax returns and one pattern count of criminal fraud. The Steeds later filed a motion challenging the constitutionality of the Asset Preservation Statute, both facially and as applied. The district court denied the motion. Joan subsequently conceded the issue of technical mootness but argued that the mootness exception applied. The Supreme Court dismissed the case, holding that this case was moot and that Joan’s claims did not warrant the application of the mootness exception. View "State v. Steed" on Justia Law

Employer, a steel mill, fired Employee on suspicion that Employee had misappropriated steel from the company. In firing him, Employer refused to pay Employee the commissions he claimed to have earned, asserting that it could withhold the commissions as an offset against the value of the misappropriated steel. Employee filed this action claiming that Employer had violated the Utah Payment of Wages Act (UPWA). The district court granted summary judgment for Employee, concluding that the UPWA did not permit a preemptive withholding of Employee’s commissions. The Supreme Court reversed, holding that the statute allows an employer in a case such as this one to seek a post-withholding opinion of a court or administrative law judge that an offset was warranted. Remanded for a determination whether Employer had presented evidence that in the opinion of the district court would warrant an offset sufficient to justify Employer’s withholding of Employee’s unpaid commission. View "Utley v. Mill Man Steel, Inc." on Justia Law

Angie Moffo lived rent free for eight years in a home owned by her brother-in-law, Doug Rich. After Rich filed for Chapter 7 bankruptcy, the appointed bankruptcy trustee, Stephen Rupp, filed suit against Moffo for back rent under Utah’s Uniform Fraudulent Transfer Act, asserting that Rich had defrauded his creditors by allowing Moffo to live in the house rent free after he became insolvent. The district court concluded that Moffo was the recipient of a fraudulent transfer and entered a $34,200 judgment against Moffo. The Supreme Court vacated the judgment entered against Moffo, holding that Rich did not transfer an asset to Moffo within the scope of the Act because the home was fully encumbered by a mortgage, and any rents were not the property of Rich. Remanded with instructions to enter summary judgment in favor of Moffo. View "Rupp v. Moffo" on Justia Law

Pursuant to a plea-in-abeyance agreement, Defendant pled no contest to charges of possession and use of a controlled substance and possession of drug paraphernalia. Defendant successfully complied with the terms of the agreement, and the justice court withdrew the plea of no contest and dismissed the two drug charges. Thereafter, Defendant filed an action under the Post-Conviction Remedies Act (PCRA) seeking to withdraw his plea in abeyance, arguing that his attorney provided ineffective assistance by improperly advising him that the abeyance plea carried no immigration consequences. The district court granted the State’s motion to dismiss, concluding that the court could not consider Defendant’s PCRA claim because the only relief available under the PCRA is to set aside a conviction, and the Legislature “did not intend a plea in abeyance to function as either a judgment or a conviction.” The Supreme Court affirmed, holding (1) the district court correctly concluded that Defendant did not qualify for relief under the PCRA because he was never convicted; and (2) the Court declines to exercise its constitutional power to fashion an alternate remedy because Defendant may obtain relief for the alleged ineffective assistance of counsel by filing a Utah R. Civ. P. 60(b)(6) motion in the justice court. View "Meza v. State" on Justia Law

After a jury trial, Defendant was found guilty of interference with an arresting peace officer and unlawful possession of another’s identification documents. Defendant appealed his conviction for unlawfully possessing another’s Social Security card, asserting that there was insufficient evidence to support a reasonable inference that he knew he was not entitled to possess the card. The court of appeals affirmed. The Supreme Court reversed, holding that the evidence presented to the jury was insufficient to sustain a reasonable inference that Defendant knew he was not entitled to possess the Social Security card. View "Salt Lake City v. Carrera" on Justia Law

After a jury trial, Defendant was convicted of twelve felony counts of unlawful discharge of a firearm. The charges stemmed from Defendant’s act of firing twelve shots at a house in a gang-related drive-by shooting. The trial court merged the twelve counts and sentenced Defendant on the basis of one conviction. The court of appeals reversed and ordered the trial court to resentence Defendant on all twelve convictions. The Supreme Court affirmed, holding that it was permissible for a jury to convict Defendant of twelve counts of unlawful discharge of a firearm in this case because the allowable unit of prosecution for unlawful discharge of a firearm is each discrete shot. View "State v. Rasabout" on Justia Law

This case involved a certification and statement of facts requesting a grand jury filed by the Salt Lake County District Attorney. After a hearing, a special panel of five district judges denied the State’s request, finding that the State had not established good cause to summon a grand jury. Thereafter, the State filed a petition for extraordinary relief in the Supreme Court, claiming that the panel abused its discretion by denying the State’s request. The Supreme Court denied the State’s petition for extraordinary relief, holding (1) the Court’s power to issue extraordinary writs gives it jurisdiction to review the panel’s decisions; but (2) the panel did not abuse its discretion in this case, as it acted exactly as it was statutorily directed to act and employed its discretion with care and impartiality. View "State v. Hon. Christiansen" on Justia Law