Justia Utah Supreme Court Opinion Summaries

David Garver and Katheryn Garver filed a medical malpractice action against several medical providers. The claims brought by David were referred to arbitration. The Garvers filed an appeal after the arbitration panel issued its decision but before the district court issued a judgment conforming to the arbitration award. The district court subsequently dismissed the Garvers’ claims. The Garvers filed a motion pursuant to Utah R. Civ. P. 60(b) arguing that the district court had been divested of jurisdiction by their premature notice of appeal, and therefore, the district court lacked jurisdiction to enter the judgment. The district court agreed and purported to reissue the judgment. The Garvers then filed another notice of appeal. The Supreme Court dismissed the appeal, holding (1) the district court had jurisdiction to issue its original judgment and erred in assuming it was divested of jurisdiction by the Garvers’ premature notice of appeal; and (2) because the Garvers failed to timely appeal the original judgment, the Court lacked jurisdiction to address any challenge to the merits. View "Garver v. Rosenberg" on Justia Law

A police officer filed a citation issued against Appellant for an open container offense in justice court, thus initiating a criminal case against Appellant. After Appellant failed to appear or forfeit bail on her justice court charge, prosecutors filed an information in district court charging Appellant with DUI, an alcohol-restricted driver offense, and an open container violation. Appellant subsequently paid her justice court fine, thus accepting a conviction in justice court on the open container offense. Despite the justice court conviction, prosecutors moved forward on the information filed in the district court. Defendant moved to dismiss. The district court (1) dismissed the open container charge, determining that the Double Jeopardy Clause prohibited a serial prosecution on that charge; but (2) denied Appellant’s motion to dismiss the other two charges, concluding that the charges were not precluded by Utah Code 76-1-403, which adopts a principle of criminal claim preclusion for offenses arising out of a “single criminal episode.” The Supreme Court affirmed the denial of Appellant’s motion to dismiss the remaining two charges, holding that the preclusion principle in section 403 was inapplicable in this case because there was no “prosecuting attorney” involved in Appellant’s first offense. View "State v. Ririe" on Justia Law

Appellant was convicted of first-degree murder and sentenced to death. After appealing, Appellant began pursuing postconviction relief. More than two years after Appellant’s second petition for postconviction relief under Utah’s Post Conviction Remedies Act (PCRA) was denied, Appellant filed a Utah R. Civ. P. 60(b) motion for relief from the denial of the second petition on the basis of newly discovered evidence. The district court denied Appellant’s Rule 60(b) motion as untimely. Appellant subsequently filed a new petition for postconviction relief based upon the same newly discovered evidence presented in his Rule 60(b) motion. The clerk of court, however, did not assign the third petition a new case number but instead filed it under the case number already assigned to the second petition. As a result, the court granted the State’s motion to dismiss the third petition for lack of jurisdiction. Appellant appealed from both the denial of his Rule 60(b) motion and the dismissal of his third petition. The Supreme Court (1) affirmed the district court’s denial of Appellant’s Rule 60(b) motion; but (2) reversed the court’s dismissal of the third petition, holding that the district court had subject matter jurisdiction over the third petition regardless of the case number assigned to it. View "Carter v. State" on Justia Law

Father and Mother conceived a child together in Pennsylvania. Due to their age difference, the sexual relationship between Mother and Father was prohibited by Pennsylvania criminal law. Mother placed the child for adoption in Utah. After Father became aware of the adoptive parents’ adoption petition he filed a motion to intervene in the Utah adoption proceedings. The district court denied the motion to intervene, citing Utah Code 78B-6-111, which forbids a biological father from challenging an adoption when his child was conceived as a result of conduct that “would constitute any sexual offense” described in the Utah Criminal Code. The Supreme Court reversed, holding that section 78B-6-111 does not apply in this case because the statute does not apply to sexual conduct lacking any jurisdiction nexus in Utah. View "In re Adoption of J.M.S." on Justia Law

Duane Serrano was injured in a car accident while driving a truck within the scope of his employment with Provo City. More than four years later, Serrano quit his job. Serrano subsequently applied for permanent total disability compensation under the Workers’ Compensation Act. On remand, an administrative law judge (ALJ) found that the preponderance of the evidence showed that Serrano was permanently and totally disabled as a result of his accident and awarded him permanent disability payments. The Utah Labor Commission affirmed. The Supreme Court affirmed, holding (1) Serrano proved the elements of a permanent total disability claim; (2) the ALJ did not abuse her discretion by initially denying Serrano’s claim but then awarding benefits after the Labor Commission instructed her to reconsider the evidence; and (3) award of benefits should not commence on the date that Serrano was deemed to be permanently and totally disabled because of the extraordinary delay in resolving Serrano’s claim. View "Provo City v. Utah Labor Comm’n" on Justia Law

Amy Sawyer was a special education teacher for the Jordan School District. When Sawyer received a failing score for her second Jordan Performance Appraisal System (JPAS) evaluation, Sawyer was informed that she would be required to pass a third JPAS evaluation to keep her job or that she could resign in order to avoid the third evaluation. Concerned that if she were terminated that she would not find future employment as a teacher, Sawyer elected to resign rather than submit to a third JPAS evaluation. The Department of Workforce Services (DWS) denied Sawyer’s application for unemployment benefits based upon its finding that Sawyer quit her job without good cause. An administrative law judge (ALJ) upheld DWS’s decision, and the Workforce Appeals Board affirmed. The Supreme Court reversed, holding (1) good cause to quit is a fact-like mixed question of law and fact reviewed deferentially; but (2) the ALJ and Appeals Board applied an incorrect legal standard to this mixed question. Remanded. View "Sawyer v. Dep’t of Workforce Servs." on Justia Law

Child was conceived in Colorado. Mother later traveled to Utah where she gave birth to Child and placed it for Adoption. Mother never told Father of her plans to come to Utah and to proceed with the adoption in Utah. After learning of Child’s birth in Utah, Father filed a petition to establish paternity in a Utah district court. The district court granted summary judgment for Mother and the adoption agency (collectively, Respondents), concluding that Utah Code 78B-6-122 required Father to affirmatively establishing paternity before acquiring any right to notice of an adoption proceeding, and because Father failed to follow these steps under Colorado law to establish paternity, Father forfeited any rights he may have had to contest the adoption under Utah law. The Supreme Court reversed, holding that section 78B-6-122 merely required Father to fulfill the requirements of Colorado law to protect his interests as a father, and because Father’s parental rights would have remained intact under Colorado law until he was given notice and an opportunity to be heard, his parental rights were likewise preserved under Utah law. View "Nevares v. M.L.S." on Justia Law

Since 1971, a monument displaying a representation of the Ten Commandments tablets has stood in a park owned by the City of Pleasant Grove. In 2003, Summum, a corporation sole and church, offered to donate and erect a “Seven Aphorisms” monument in the park that was similar to the Ten Commandments monument. The City declined Summum’s offer. After unsuccessfully suing in federal court, Summum sued in federal court. The United States Supreme Court concluded that the placement of a monument on public property was a form of government speech not regulated by the Free Speech Clause. Summum subsequently sued in state court, alleging that the City had violated the religious liberty clause of the state Constitution and seeking an injunction requiring the City to display the Seven Aphorisms monument. The district court granted summary judgment for the City. The Supreme Court affirmed, holding that the religious liberty clause of the Utah Constitution does not require the district court to force the City to permanently display the Seven Aphorisms monument because the neutrality test adopted in Soc’y of Separationists v. Whitehead to determine whether a government action amounts to an unconstitutional appropriation of public money for religious exercise does not apply in the context of public monuments. View "Summum v. Pleasant Grove City" on Justia Law

Appellees alleged claims for tortious interference with economic relations against Appellant. The tortious interference theories each rested on two separate allegations: first, that Appellant had interfered with Appellees’ economic relations through an improper means; and second, that Appellant had interfered with Appellees’ economic relations in pursuit of an improper purpose. The district court partially granted Appellant’s motion for summary judgment, concluding (1) there was no evidence that Appellant had interfered with Appellees’ economic relations through an improper means; but (2) Appellant was not entitled to summary judgment on Appellees’ tortious interference claims insofar as they were based on the allegation that Appellant had acted with an improper purpose. The Supreme Court reversed, hereby rejecting the improper-purpose rule, holding that, contrary to Leigh Furniture & Carpet Co. v. Isom, a claim for tortious interference may only succeed where the defendant has employed an improper means. View "Eldridge v. Johndrow" on Justia Law

After a jury trial, Defendant was convicted of first-degree rape. The Supreme Court reversed, holding (1) trial counsel was ineffective for failing to object to a jury instruction misstating the requirement of mens rea as applied to the elements of first-degree rape; and (2) the statutory standard for nonconsent under Utah Code 76-5-406 does not establish the sum and substance of all circumstances amounting to nonconsent but simply prescribes the circumstances in which the legislature forecloses a jury finding of consent as a matter of public policy. The Court also clarified and the standard for granting a defendant’s request for a victim’s medical records under Utah R. Crim. P. 14(b). View "State v. Barela" on Justia Law