Justia Utah Supreme Court Opinion Summaries

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

At dispute in this case was compensation paid to Attorney by Law Firm for work Attorney performed on several class-action contingency fee cases involving the weight-loss pill Fen-Phen. Attorney was paid approximately fifteen percent of the fees generated by the Fen-Phen cases. Attorney filed suit claiming (1) the parties agreed that the general compensation agreement, which entitled Attorney to eighty percent of the fees he generated from hourly work, would apply to the fees generated by the Fen-Phen litigation; (2) under quantum meruit, Law Firm and additional defendants were unjustly enriched by his work; and (3) a second law firm that worked on the Fen-Phen litigation and received a portion of the fees was liable to him under Utah’s Fraudulent Transfer Act (FTA). The district court dismissed Attorney’s contract claim and concluded that Attorney failed to establish that he provided services more than the amount he received from the Fen-Phen fees. The Supreme Court (1) affirmed the dismissal of Attorney’s contract claim; (2) reversed the denial of Attorney’s jury demand and, sending the claim back to the jury, clarified the correct measure of damages on the quantum meruit claim; and (3) upheld the dismissal of the individual defendants from both the quantum meruit claim and the FTA claim. View "Jones v. Mackey Price Thompson & Ostler" on Justia Law

In 2006 and 2007, Respondent lent Petitioners, a group of real estate investors, over $170,000. When the real estate bubble burst the next year, Petitioners defaulted on the loans. Following more than a year of pretrial litigation, the district court entered default judgment against Petitioners because of their repeated failure to meet discovery deadlines. Petitioners appealed, arguing that their discovery failures did not merit the sanction of default and that the default judgment could not be entered on some claims because Respondent’s complaint had not alleged sufficient facts to support relief. The court of appeals affirmed, concluding that the district court did not abuse its discretion in entering default judgment. The court refused to consider the second set of arguments because they had not been preserved. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in entering default; and (2) the court of appeals correctly determined that it should not consider the issue of the complaint’s legal sufficiency because that issue had not been preserved. View "Fu v. Rhodes" on Justia Law

Appellant was convicted of two counts of aggravated murder and related crimes. The Supreme Court affirmed. Thereafter, Appellant filed a petition for relief under the Post-Conviction Remedies Act (PCRA), claiming that newly discovered evidence in the form of testimony from two new witnesses would exonerate him and that the State violated his due process rights by knowingly introducing perjured testimony and fabricating evidence at trial. The district court dismissed Appellant’s PCRA claims. The Supreme Court affirmed, holding (1) because Appellant failed to demonstrate that no reasonable jury could enter a judgment of conviction in light of the new testimony, Appellant’s newly discovered evidence claims failed on their merits; (2) Appellant’s due process claims were procedurally barred because they could have been but were not brought at trial or on appeal; and (3) the district court did not abuse its discretion in denying Appellant’s motions for discovery and to amend his PCRA pleadings. View "Pinder v. State" on Justia Law

In this personal injury action arising out of an automobile accident, Robert and Terri Zeller filed a complaint against Charlotte Nixon alleging claims for negligence and loss of consortium. The Zellers submitted their claims for arbitration under Utah Code 31A-22-321, which provides that the election of arbitration stands unless a notice of rescission is filed within ninety days. After the ninety-day rescission period had passed, the Zellers moved to amend their complaint to add a claim for negligent entrustment against Nixon & Nixon, Inc. Nixon opposed the motion to amend and filed a motion to compel arbitration. The district court denied the motion to compel arbitration, concluding that the Zellers were justified in seeking the amendment, thus freeing the Zellers of the statutory limitations on their claims against Nixon and allowing their claims to proceed against Nixon & Nixon. The Supreme Court (1) reversed as to the claims against Nixon, as those claims were irretrievably subject to arbitration given the Zellers’ failure to rescind their election of arbitration within ninety days; and (2) affirmed as to the claims against Nixon & Nixon, holding that the Zellers’ earlier election of arbitration as to their claim against Nixon did not encompass their subsequent claim against the corporation. View "Zeller v. Nixon" on Justia Law

Orlando Millenia (Plaintiff), the lender on a multi-million dollar real estate transaction, filed this suit alleging that United Title Services of Utah, Inc. breached its fiduciary duty as an escrow agent in the property transaction. In addition, Plaintiff asserted claims for vicarious liability against Stewart Title Insurance Co. and First American Title Insurance Co. under Utah Code 31A-23a-407, a provision that Plaintiff viewed as imposing vicarious liability on Stewart and First American for United Title’s actions as escrow agent. The district court granted summary judgment in favor of Defendants. The Supreme Court reversed, holding (1) Plaintiff stated a claim for breach of fiduciary duty that survived Defendants’ motions for summary judgment; and (2) Plaintiff successfully stated a claim for vicarious liability under section 407. View "Orlando Millenia, LC v. United Title Servs. of Utah, Inc." on Justia Law

Defendant was charged with aggravated murder, child kidnapping, and rape of a child. The case was assigned to Judge Kouris. Two weeks before the preliminary hearing, defense counsel filed a petition to evaluate Defendant’s competency to stand trial. Judge Kouris was scheduled to preside over Defendant’s competency evaluation. Defendant filed a motion to transfer adjudication of the competency petition to another judge, arguing that his competency evaluation must be adjudicated by a different judge because Judge Kouris had sat as magistrate in the case. The district court denied the motion to transfer. Defendant then moved to disqualify Judge Koruis, arguing that the judge created an appearance of bias. The district court denied the motion. The Supreme Court affirmed, holding (1) the disqualification issue became moot when Judge Kouris was transferred to a different court docket, causing this case to be reassigned during the pendency of this appeal; and (2) a district court judge retains the authority to act as both a magistrate and a judge in the same criminal case. View "State v. Black" on Justia Law

This case involved a lease agreement between Greyhound Lines, Inc., the lessee, and Utah Transit Authority (UTA), the lessor, for a section of UTA’s intermodal transportation facility (intermodal hub). The insurance procurement provision of the lease agreement required Greyhound to purchase commercial general liability insurance covering UTA. At issue was whether the provision required that this insurance cover UTA’s negligent acts. This litigation resulted from a Greyhound passenger’s fall from a concrete pedestrian ramp during a layover at the intermodal hub. UTA admitted negligence in not installing a handrail on the pedestrian ramp. UTA settled the injured passenger’s claim and requested that Greyhound reimburse it for the cost of the claim under the lease agreement. Greyhound refused. The district court entered judgment against Greyhound. The Supreme Court affirmed, holding (1) under Utah law, an agreement to procure insurance for the benefit of another is not subject to strict construction; (2) the district court did not err when it concluded that the injured passenger’s claim triggered Greyhound’s duty to procure insurance that covered UTA’s negligent acts; and (3) the district court did not abuse its discretion in awarding UTA’s attorney fees. View "Utah Transit Auth. v. Greyhound Lines, Inc." on Justia Law

Appellant pleaded guilty to first-degree murder in 1988. Appellant later filed a motion to withdraw his plea. The district court denied the motion on the merits. The Supreme Court affirmed. In 2014, Appellant filed a motion to reinstate his right to appeal under Utah R. App. P. 4(f), claiming that his counsel had rendered ineffective assistance in advising him to accept the plea. The district court concluded that the allegations did not satisfy the criteria set forth by rule 4(f). Appellant’s appeal was transferred to the court of appeals under Utah R. App. P. 42(a). Appellant argued that the appeal was not subject to transfer. The Supreme Court issued an order temporarily recalling the transfer of this appeal for the purpose of determining whether it was within the Court’s exclusive jurisdiction. The Supreme Court transferred this appeal back to the court of appeals, concluding that this appeal was not within the Court’s exclusive appellate jurisdiction because the decision from which Appellant’s appeal was brought only denied a postjudgment request to reinstate the right to appeal, and Appellant’s appeal of that decision did not constitute a direct challenge to his conviction. View "State v. Smith" on Justia Law

During a rainstorm a culvert under a state road became obstructed, causing water to back up on the side of the road. Utah Department of Transportation (UDOT) workers tried to unclog the culvert but were unsuccessful and subsequently left the scene. The pooled water eventually caused the road to collapse. That night, Plaintiffs’ vehicles careened into the chasm, injuring two people and killing a fifteen-year-old. Plaintiffs sued UDOT, alleging negligent maintenance of the road and the clogged culvert. The district court granted summary judgment for UDOT, concluding that it was immune under the Governmental Immunity Act. The Supreme Court reversed, holding that UDOT failed to meet its burden of establishing that there was no genuine issue of material fact and that it was entitled to judgment as a matter of law. View "Barneck v. Utah Dep’t of Transp." on Justia Law