Justia Utah Supreme Court Opinion Summaries

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

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

After a jury trial held in 1999, Appellant was convicted of murder and tampering with evidence. The convictions were affirmed on appeal and upheld on multiple postconviction challenges in both state and federal court. Appellant here filed a petition for postconviction DNA testing, claiming that DNA testing will show his factual innocence. The district court denied Appellant’s petition, concluding that the DNA testing did not have the potential to produce new, noncumulative evidence that would establish Appellant’s factual innocence under Utah Code 78B-9-301(2)(f). The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court’s analysis of the operative terms of the statute was only partially in accordance with the law. Remanded. View "Meinhard v. State" on Justia Law

After a jury trial held in 1999, Appellant was convicted of murder and tampering with evidence. The convictions were affirmed on appeal and upheld on multiple postconviction challenges in both state and federal court. Appellant here filed a petition for postconviction DNA testing, claiming that DNA testing will show his factual innocence. The district court denied Appellant’s petition, concluding that the DNA testing did not have the potential to produce new, noncumulative evidence that would establish Appellant’s factual innocence under Utah Code 78B-9-301(2)(f). The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court’s analysis of the operative terms of the statute was only partially in accordance with the law. Remanded. View "Meinhard v. State" on Justia Law

M.J. was allegedly required to enter into an underage marriage at the direction of Warren Jeffs, then the head of the Fundamentalist Church of Jesus Christ of Latter-Day Saints and trustee of the United Effort Plan Trust. M.J. filed suit against Jeffs and Bruce Wisan, in his capacity as special fiduciary of the Trust, asserting a variety of tort claims and claims for both vicarious and direct liability against the Trust. The Trust filed a series of motions for summary judgment, all of which were denied. The Supreme Court affirmed the denial of summary judgment in large part, upholding that district court’s decisions on all issues except its determination that the Trust is subject to liability on reverse veil-piercing grounds, holding that the Trust was entitled to summary judgment on that limited basis. View "M.J. v. Wisan" on Justia Law

Plaintiff was injured when forced to stop suddenly near a construction crew on a Utah road. Plaintiff submitted a notice of claim against the Utah Department of Transportation (UDOT). UDOT did not respond to the notice of claim within sixty days, and therefore, Plaintiff’s claim was deemed denied. One month later, UDOT sent a letter to Plaintiff stating that UDOT denied the claim. Plaintiff subsequently filed suit against UDOT and several unnamed “John Does.” UDOT moved for summary judgment, arguing that the Utah Governmental Immunity Act (GIA) barred Plaintiff’s claim because he did not file within one year of the date on which it was deemed denied. The trial court granted UDOT’s motion and dismissed Plaintiff’s entire suit with prejudice, including his claim against the Doe Defendants. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the denial letter sent after the deemed denial had occurred did not restart the limitations period and was a legal superfluity, and therefore, Plaintiff did not timely file his suit under the GIA; (2) estoppel was not warranted in this case; and (3) the dismissal of the Doe Defendants was proper where they were described as employees of UDOT. View "Monarrez v. Utah Dep’t of Transp." on Justia Law