Justia Utah Supreme Court Opinion Summaries

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The United States District Court for the District of Utah certified questions of law to the Supreme Court regarding Qualified Political Parties (QPP). The first question asked whether Utah law requires that a QPP permit its members to seek its nomination by either or both of the methods set forth in Utah Code 20A-9-407 and 20A-9-408 or whether a QPP may preclude a member from seeking the party’s nomination by gathering signatures under section 20A-9-408. The second question asked whether the Lieutenant Governor must treat a registered political party (RPP) that has selected to be designated as a QPP as a RPP under Utah law. The Supreme Court answered (1) Utah Code 20A-9-101 requires that QPP party members may choose the method of candidacy qualification; and (2) the certified question regarding the Lieutenant Governor’s obligations is hypothetical and not ripe for decision. View "Utah Republican Party v. Cox" on Justia Law

Posted in: Election Law
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Plaintiff ClearOne is a Utah corporation and Defendant Revolabs is a competitor incorporated in Delaware with its principal place of business in Massachusetts. The underlying dispute arose when Revolabs recruited and hired Timothy Mackie while he was still employed by ClearOne. ClearOne brought this suit in Utah district court, alleging intentional interference with a contractual relationship, predatory hiring, and aiding and abetting a breach of fiduciary duty. Revolabs filed a motion to dismiss for lack of personal jurisdiction. The trial court granted the motion. The Supreme Court affirmed, holding (1) ClearOne failed to allege that Revolabs had sufficient minimum contacts to subject it to specific personal jurisdiction in Utah; and (2) the trial court did not abuse its discretion in denying discovery to determine whether Revolabs was subject to general personal jurisdiction in Utah. View "ClearOne, Inc. v. Revolabs, Inc." on Justia Law

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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

Posted in: Injury Law
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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

Posted in: Injury Law
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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

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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

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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law