Justia Utah Supreme Court Opinion Summaries

Utah’s pay-TV sales tax scheme provides a sales tax credit for an amount equal to fifty percent of the franchise fees paid by pay-TV providers to local municipalities for use of their public rights-of-way. Satellite providers, however, use a different business model that does not trigger franchise fees. The satellite providers brought this lawsuit asserting that Utah’s tax scheme favors local economic interests at the expense of interstate commerce in violation of the Commerce Clause and the Uniform Operation of Laws Clause. The State Tax Commission moved for judgment on the pleadings. The district court granted the motion. The Supreme Court affirmed, holding (1) Utah’s pay-TV tax credit survives dormant commerce scrutiny; and (2) the tax credit survives rational basis scrutiny under the Uniform Operation of Laws Clause. View "DIRECTV v. Utah State Tax Comm’n" on Justia Law

K.C., a minor child, was removed from the custody of her mother. Nearly seventeen months after K.C. had originally been removed from Mother’s custody and after a permanency hearing, the juvenile court terminated reunification services. The State then filed a petition for termination of parental rights. Mother argued that Department of Child and Family Services had not complied with the Americans with Disabilities Act (ADA) and that, therefore, the State was incapable of making “reasonable efforts” toward reunification. The juvenile court determined that the ADA is not a defense in a termination proceeding and, even if the ADA applied, Mother had not suffered from any failure to comply with the ADA because Mother’s disabilities were accommodated. The court then terminated Mother’s parental rights. The Supreme Court affirmed, holding (1) the ADA applies to the provision of reunification services under Utah Code 78A-6-312 and 78A-6-507; but (2) the juvenile court judge did not abuse his discretion in deciding that Mother’s requested modifications to the reunification plan in question were not reasonable. View "In re K.C." on Justia Law

628 Park Avenue, LLC filed a complaint asserting claims for unlawful detainer, breach of a promissory note, breach of lease, and declaratory relief against James Ring and other defendants. A default judgment was entered against Ring. The judgment, however, was nonfinal because claims against other defendants remained pending when it was entered. Because 628 Park Avenue recorded the default judgment it claimed to have acquired a judgment lien. The district court concluded that 628 Park Avenue possessed a valid judgment lien against the property in the amount of the original default judgment. The Court of Appeals affirmed. The Supreme Court reversed, holding (1) the judgment sustaining a lien under Utah Code 78B-5-202(7) must be a final judgment; and (2) the recorded judgment in this case was insufficient because it merely identified the judgment debtor by name and did not provide sufficient information as required by section 78B-5-202(7)(a)(i). View "Irving Place Assocs. v. 628 Park Ave, LLC" on Justia Law

Defendant was parked on the side of a highway with his hazard lights flashing when two sheriff’s deputies stopped to check on his welfare. The officers subsequently discovered marijuana in Defendant’s vehicle. The State charged Defendant with possession of marijuana and possession of drug paraphernalia. Defendant moved to suppress the evidence obtained from his vehicle. The district court denied the motion to suppress, ruling that the stop was justified by the community caretaking doctrine. After a jury trial, Defendant was convicted of the charges. Defendant appealed the denial of his motion to suppress. The Supreme Court affirmed, holding (1) the deputies seized Defendant when they pulled behind his parked vehicle with blue and red lights flashing; but (2) the community caretaking doctrine justified the stop under the facts of this case, and therefore, the seizure did not violate the Fourth Amendment. View "State v. Anderson" on Justia Law

For several years ASC Utah, Inc. operated a ski resort on land adjacent to that owned by Plaintiffs. Plaintiffs authorized ASC to use their land in exchange for an annual payment. Plaintiffs filed this action asserting that ASC breached the contract by mismanaging the property. Plaintiffs asserted claims for breach of the covenant of good faith and fair dealing, for injunctive relief, and for equitable rescission or reformation of the agreement. A jury resolved the first claim against Plaintiffs. The district court resolved the remaining claims after a bench trial in a decision that denied injunctive relief and refused to terminate the agreement but reformed it in part. The Supreme Court vacated the portion of the portion of the trial court’s order purporting to dispose of the rights of Plaintiffs to payments tendered by ASC but rejected by Plaintiffs and otherwise affirmed, holding (1) because Plaintiffs failed to file a notice of appeal as to the jury verdict, the Court lacked jurisdiction over matters resolved in the course of the jury; (2) the trial court did not abuse its discretion in refusing to award injunctive relief; and (3) the trial court did not err in deciding to reform the contract prospectively in part. View "Osguthorpe v. ASC Utah, Inc." on Justia Law

After a jury trial, Defendant was convicted of aggravated murder and aggravated kidnapping, among other crimes. The Supreme Court affirmed Defendant’s convictions, holding (1) Defendant failed to establish that prosecutor committed misconduct by calling Defendant’s codefendant to testify when the codefendant had indicated an intention to invoke his Fifth Amendment privilege against self-incrimination, and therefore, the trial court did not abuse its discretion in denying Defendant’s motion for a mistrial; (2) because Defendant did not demonstrate prejudice from the prosecutor’s use of leading questions in questioning the codefendant, Defendant meet his burden of demonstrating prejudice for his unpreserved federal constitutional claim; and (3) Defendant’s lawyers were not ineffective for failing to move to merge the conviction for aggravated kidnapping with the conviction for aggravated murder because such a motion would have been futile. View "State v. Bond" on Justia Law

Brian Wade, in the course of servicing a well situated under a high voltage line owned by Flowell Electric Association and Dixie Escalante Rural Electric Association, Inc. (collectively, Flowell), came into contact with the line, resulting in serious injuries to Wade. Wade was acting on behalf of Rhodes Pump II, LLC, his employer, at the time of the accident. Wade received workers’ compensation benefits from Rhodes and also filed a tort action against Flowell. A jury returned a verdict in favor of Wade and awarded both compensatory and punitive damages. Flowell subsequently brought this action for High Voltage Overhead Lines Act (HVOLA) indemnification against Rhodes. The district court granted summary judgment in favor of Flowell, concluding that Rhodes had failed to give Flowell adequate notice of its “intended activity.” The Supreme Court reversed, holding (1) Flowell timely filed its HVOLA indemnification action; (2) the Workers’ Compensation Act’s exclusive remedy provision does not preclude liability under the HVOLA; (3) HVOLA does not violate due process or equal protection as applied to Rhodes; and (4) a genuine issue of material fact remains regarding whether Rhodes adequately notified Flowell of its intended activity. View "Flowell Elec. Ass’n v. Rhodes Pump, LLC" on Justia Law

Petitioners, four of the prospective sponsors of a proposed referendum petition, asserted that they prepared and attempted to submit a referendum application but were denied the opportunity based on Utah Code 20A-7-302, which states that “persons wishing to circulate a referendum petition shall file an application with the lieutenant governor within five calendar days after the end of the legislative session at which the law passed.” The petition implied that the five-day deadline is unconstitutional because referenda sponsors, as a practical matter, cannot comply. The Supreme Court declined to grant the requested relief, holding that even if the Court accepted the petition’s factual allegations, Petitioners failed to provide the Court with a sound basis for declaring Utah Code 20A-7-302 unconstitutional on its face or as applied to the facts they alleged. View "Gricius v. Cox" on Justia Law

Donald Rawlings, the eldest of five siblings, claimed full ownership of farmland deeded to him by his father. Donald’s siblings sought to maintain a constructive trust over the farm property and its equal division among the children, claiming that their father never intended to vest sole ownership in Donald and to their permanent exclusion. In Rawlings I, the Supreme Court upheld a district court order imposing a constructive trust over the property in favor of the siblings under a theory of unjust enrichment. On remand, the district court permitted additional discovery to resolve the issue of what properties should be included within the constructive trust. When Donald did not adequately respond to the siblings’ discovery requests, the district court entered an order to compel. When Donald failed to comply with that order, the district court granted the siblings’ request to strike Donald’s pleadings and defenses and entered default judgment against him. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in entering default judgment against Donald; and (2) under the mandate rule, Donald may not challenge the imposition of the constructive trust. View "Rawlings v. Rawlings" on Justia Law

Plaintiffs, several employees of Wal-Mart, were involved in physical confrontations with shoplifting customers and were ultimately fired for violating company policy. Plaintiffs filed this action against Wal-Mart in federal district court for wrongful termination, alleging that terminating a person’s employment for exercising self-defense in the workplace violates Utah public policy. The federal district court certified to the Supreme Court the question of whether self-defense is a substantial public policy exception to the at-will employment doctrine, thus providing a basis for a wrongful termination action. The Supreme Court held that the policy favoring the right of self-defense is a public policy of sufficient clarity and weight to qualify as an exception to the at-will employment doctrine, but the exception is limited to situations where an employee reasonably believed that force was necessary to defend against an imminent threat of serious bodily harm under circumstances where he or she was unable safely to withdraw. View "Ray v. Wal-Mart Stores, Inc." on Justia Law