Justia Utah Supreme Court Opinion Summaries

Plaintiff filed suit against the United States in a federal district court alleging that medical staff at the VA medical center in Salt Lake City negligently caused his son’s death. The district court certified two questions to the Utah Supreme Court asking whether the noneconomic damages cap in section 78B-3-410 of the Malpractice Act permissible as applied to wrongful death cases under Utah Const. art. XVI, 5, which prohibits damage caps in wrongful death cases. The Supreme Court held that the damages cap in section 78B-3-410 is unconstitutional as applied to cases of wrongful death under article XVI, section 5 of the Utah Constitution. View "Smith v. United States" on Justia Law

In an equalization proceeding before the Utah State Tax Commission, Decker Lake Ventures, LLC sought a reduction of the assessed valuation of its property under Utah Code 59-2-1006. Under this statute, the Commission is directed to “adjust property valuations to reflect a value equalized with the assessed value of other comparable properties” upon a determination that “the property that is the subject of the appeal deviates in value plus or minus 5% from the assessed value of comparable properties.” The Commission rejected Decker Lake’s equalization claim. The Supreme Court affirmed, holding that the Commission did not commit reversible error in its determination of comparability or in its factual findings. View "Decker Lake Ventures v. Utah State Tax Comm'n" on Justia Law

Plaintiffs brought this medical malpractice action against Defendant, a medical doctor, for the wrongful death of their deceased father. A jury found that Defendant breached the standard of care and that this breach was the proximate cause of the death of Plaintiffs’ father. The jury awarded Plaintiff more than $3 million in general damages and $300,000 in punitive damages. The Supreme Court reversed and remanded for a new jury trial, holding that the trial court abused its discretion in admitting evidence of Defendant’s prior felony conviction under rules 608 and 609 of the Utah Rules of Evidence, and the admission of Defendant’s conviction was not harmless error. View "Robinson v. Taylor" on Justia Law

Jake Strickland was involved in a sexual relationship with W.P. while W.P. was married to someone else. When W.P. became pregnant, W.P. informed Strickland that he was the father. W.P. represented to Strickland that she would not place B.Y. up for adoption, but the day after B.Y. was born, W.P. relinquished her parental rights and placed the child for adoption. When Strickland learned of W.P.’s actions, he promptly commenced a paternity action and then moved to intervene in the pending adoption proceeding. The district court ruled that Strickland had no interest in the adoption proceeding because he failed strictly to comply with the statutory requirements for contesting B.Y.’s adoption and that “fraudulent representation” is not an excuse for failing to strictly comply with the Adoption Act. The court also rejected Strickland’s constitutional challenges to the Adoption Act. The Supreme Court affirmed, holding that Strickland had no viable interest in the child in question because he forfeited his parental rights as a result of a private bargain he struck with W.P., not because of any unconstitutional or otherwise unlawful state action. View "In re B.Y." on Justia Law

Defendant was charged with eleven counts related to his alleged sexual abuse of C.E. The State requested that a magistrate bind Defendant over for trial. After a hearing, the magistrate concluded that the evidence was so contradictory, inconsistent, and unbelievable that she need not “give credence” to C.E.’s testimony. Because the case depended “solely on the testimony of [C.E.]”, the magistrate granted Defendant’s motion to dismiss the charges, finding that the prosecution failed to present sufficient evidence to support a reasonable belief that Defendant committed the crimes charged. The First Circuit reversed the magistrate’s decision, holding (1) the magistrate exceeded her discretion in disregarding C.E.’s testimony because there was at least a reasonable inference from the evidence that C.E. was telling the truth; and (2) the magistrate exceeded her discretion in refusing to bind Defendant over for trial because C.E.’s testimony described daily sexual abuse over a four-year period. View "State v. Schmidt" on Justia Law

Plaintiff, an attorney, filed a complaint against his employer, alleging that he was terminated for refusing to violate the Utah Rules of Professional Conduct. Specifically, Plaintiff alleged that he was fired for refusing to break the law by complying the company’s ongoing violation of usury laws in numerous states. The district court dismissed the complaint, concluding that Plaintiff was an at-will employee and that his termination did not violate a clear and substantial public policy of the state. The Supreme Court affirmed, holding (1) the district court properly dismissed Plaintiff’s wrongful termination claim, where Plaintiff failed to invoke a clear and substantial public policy that would have prohibited his employer from terminating him, and where rule 1.13(b) of the Utah Rules of Professional Conduct does not reflect the type of public policy that prevents the termination of an at-will employee; and (2) the district court erred when it denied Plaintiff’s request for a hearing, but the error was harmless. View "Pang v. Int’l Document Servs." on Justia Law

Plaintiff, an attorney, filed a complaint against his employer, alleging that he was terminated for refusing to violate the Utah Rules of Professional Conduct. Specifically, Plaintiff alleged that he was fired for refusing to break the law by complying the company’s ongoing violation of usury laws in numerous states. The district court dismissed the complaint, concluding that Plaintiff was an at-will employee and that his termination did not violate a clear and substantial public policy of the state. The Supreme Court affirmed, holding (1) the district court properly dismissed Plaintiff’s wrongful termination claim, where Plaintiff failed to invoke a clear and substantial public policy that would have prohibited his employer from terminating him, and where rule 1.13(b) of the Utah Rules of Professional Conduct does not reflect the type of public policy that prevents the termination of an at-will employee; and (2) the district court erred when it denied Plaintiff’s request for a hearing, but the error was harmless. View "Pang v. Int’l Document Servs." on Justia Law

Utah County established an off-site work-release program for potentially dangerous inmates in its custody and screened each inmate before placing them with employers. Shawn Michael Leonard escaped while on the work-release program and assaulted Plaintiff near the Provo River Trail. Plaintiff survived, but her injuries were substantial. Plaintiff filed a negligence action against the County. The district court ruled in favor of the County, concluding that it did not owe a duty to Plaintiff and, alternatively, that the Utah Governmental Immunity Act barred all of Plaintiff’s claims. The Supreme Court affirmed the district court’s decision dismissing Plaintiff’s negligence claims against the County, holding (1) the County owed Plaintiff a duty of care because it took affirmative steps that created a risk of harm; but (2) the Governmental Immunity Act is not unconstitutional as applied in this case, where work-release programs are essential to the core governmental activity of housing and rehabilitating inmates, and therefore, governmental immunity barred Plaintiff’s claim. View "Scott v. Universal Indus. Sales" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated murder and one count of theft by receiving a stolen motor vehicle. Defendant was sentenced to life in prison without the possibility of parole on the aggravated murder counts. Defendant appealed, raising several claims of ineffective assistance of counsel. The Supreme Court granted Defendant’s motion for remand and stayed the appeal. After a hearing, the district court rejected all of Defendant’s claims. The Supreme Court affirmed Defendant’s convictions, holding that defense counsel either did not perform deficiently or that Defendant failed to show prejudice stemming from defense counsel’s alleged deficiencies. View "State v. Nelson" on Justia Law

In 1993, Appellant was convicted of sodomizing his girlfriend’s sons and with sexually assaulting a neighbor’s child. In 2009, Appellant filed a petition for post-conviction relief alleging that counsel provided ineffective assistance by failing to inform him about a plea bargain the State allegedly offered before trial. The district court dismissed the petition, concluding that it was time-barred under the Post-Conviction Remedies Act (PCRA). The Supreme Court affirmed the dismissal of most of Appellant’s claims, but before it could issue its decision, the U.S. Supreme Court decided Lafler v. Cooper and Missouri v. Frye. The Utah Supreme Court ultimately vacated the dismissal on the narrow issue of whether these decisions created a new cause of action for Appellant under the PCRA. Appellant pursued a claim based on these decisions. The district court dismissed Appellant’s claim. The Supreme Court affirmed, holding that because Lafler and Frye announced a new rule not dictated by precedent existing at the time Appellant’s conviction or sentence became final, they did not give rise to a new cause of action under the PCRA. View "Winward v. State" on Justia Law