Justia Utah Supreme Court Opinion Summaries

Angie Moffo lived rent free for eight years in a home owned by her brother-in-law, Doug Rich. After Rich filed for Chapter 7 bankruptcy, the appointed bankruptcy trustee, Stephen Rupp, filed suit against Moffo for back rent under Utah’s Uniform Fraudulent Transfer Act, asserting that Rich had defrauded his creditors by allowing Moffo to live in the house rent free after he became insolvent. The district court concluded that Moffo was the recipient of a fraudulent transfer and entered a $34,200 judgment against Moffo. The Supreme Court vacated the judgment entered against Moffo, holding that Rich did not transfer an asset to Moffo within the scope of the Act because the home was fully encumbered by a mortgage, and any rents were not the property of Rich. Remanded with instructions to enter summary judgment in favor of Moffo. View "Rupp v. Moffo" on Justia Law

Pursuant to a plea-in-abeyance agreement, Defendant pled no contest to charges of possession and use of a controlled substance and possession of drug paraphernalia. Defendant successfully complied with the terms of the agreement, and the justice court withdrew the plea of no contest and dismissed the two drug charges. Thereafter, Defendant filed an action under the Post-Conviction Remedies Act (PCRA) seeking to withdraw his plea in abeyance, arguing that his attorney provided ineffective assistance by improperly advising him that the abeyance plea carried no immigration consequences. The district court granted the State’s motion to dismiss, concluding that the court could not consider Defendant’s PCRA claim because the only relief available under the PCRA is to set aside a conviction, and the Legislature “did not intend a plea in abeyance to function as either a judgment or a conviction.” The Supreme Court affirmed, holding (1) the district court correctly concluded that Defendant did not qualify for relief under the PCRA because he was never convicted; and (2) the Court declines to exercise its constitutional power to fashion an alternate remedy because Defendant may obtain relief for the alleged ineffective assistance of counsel by filing a Utah R. Civ. P. 60(b)(6) motion in the justice court. View "Meza v. State" on Justia Law

After a jury trial, Defendant was found guilty of interference with an arresting peace officer and unlawful possession of another’s identification documents. Defendant appealed his conviction for unlawfully possessing another’s Social Security card, asserting that there was insufficient evidence to support a reasonable inference that he knew he was not entitled to possess the card. The court of appeals affirmed. The Supreme Court reversed, holding that the evidence presented to the jury was insufficient to sustain a reasonable inference that Defendant knew he was not entitled to possess the Social Security card. View "Salt Lake City v. Carrera" on Justia Law

After a jury trial, Defendant was convicted of twelve felony counts of unlawful discharge of a firearm. The charges stemmed from Defendant’s act of firing twelve shots at a house in a gang-related drive-by shooting. The trial court merged the twelve counts and sentenced Defendant on the basis of one conviction. The court of appeals reversed and ordered the trial court to resentence Defendant on all twelve convictions. The Supreme Court affirmed, holding that it was permissible for a jury to convict Defendant of twelve counts of unlawful discharge of a firearm in this case because the allowable unit of prosecution for unlawful discharge of a firearm is each discrete shot. View "State v. Rasabout" on Justia Law

This case involved a certification and statement of facts requesting a grand jury filed by the Salt Lake County District Attorney. After a hearing, a special panel of five district judges denied the State’s request, finding that the State had not established good cause to summon a grand jury. Thereafter, the State filed a petition for extraordinary relief in the Supreme Court, claiming that the panel abused its discretion by denying the State’s request. The Supreme Court denied the State’s petition for extraordinary relief, holding (1) the Court’s power to issue extraordinary writs gives it jurisdiction to review the panel’s decisions; but (2) the panel did not abuse its discretion in this case, as it acted exactly as it was statutorily directed to act and employed its discretion with care and impartiality. View "State v. Hon. Christiansen" on Justia Law

Plaintiff filed suit against the United States in a federal district court alleging that medical staff at the VA medical center in Salt Lake City negligently caused his son’s death. The district court certified two questions to the Utah Supreme Court asking whether the noneconomic damages cap in section 78B-3-410 of the Malpractice Act permissible as applied to wrongful death cases under Utah Const. art. XVI, 5, which prohibits damage caps in wrongful death cases. The Supreme Court held that the damages cap in section 78B-3-410 is unconstitutional as applied to cases of wrongful death under article XVI, section 5 of the Utah Constitution. View "Smith v. United States" on Justia Law

In an equalization proceeding before the Utah State Tax Commission, Decker Lake Ventures, LLC sought a reduction of the assessed valuation of its property under Utah Code 59-2-1006. Under this statute, the Commission is directed to “adjust property valuations to reflect a value equalized with the assessed value of other comparable properties” upon a determination that “the property that is the subject of the appeal deviates in value plus or minus 5% from the assessed value of comparable properties.” The Commission rejected Decker Lake’s equalization claim. The Supreme Court affirmed, holding that the Commission did not commit reversible error in its determination of comparability or in its factual findings. View "Decker Lake Ventures v. Utah State Tax Comm'n" on Justia Law

Plaintiffs brought this medical malpractice action against Defendant, a medical doctor, for the wrongful death of their deceased father. A jury found that Defendant breached the standard of care and that this breach was the proximate cause of the death of Plaintiffs’ father. The jury awarded Plaintiff more than $3 million in general damages and $300,000 in punitive damages. The Supreme Court reversed and remanded for a new jury trial, holding that the trial court abused its discretion in admitting evidence of Defendant’s prior felony conviction under rules 608 and 609 of the Utah Rules of Evidence, and the admission of Defendant’s conviction was not harmless error. View "Robinson v. Taylor" on Justia Law

Jake Strickland was involved in a sexual relationship with W.P. while W.P. was married to someone else. When W.P. became pregnant, W.P. informed Strickland that he was the father. W.P. represented to Strickland that she would not place B.Y. up for adoption, but the day after B.Y. was born, W.P. relinquished her parental rights and placed the child for adoption. When Strickland learned of W.P.’s actions, he promptly commenced a paternity action and then moved to intervene in the pending adoption proceeding. The district court ruled that Strickland had no interest in the adoption proceeding because he failed strictly to comply with the statutory requirements for contesting B.Y.’s adoption and that “fraudulent representation” is not an excuse for failing to strictly comply with the Adoption Act. The court also rejected Strickland’s constitutional challenges to the Adoption Act. The Supreme Court affirmed, holding that Strickland had no viable interest in the child in question because he forfeited his parental rights as a result of a private bargain he struck with W.P., not because of any unconstitutional or otherwise unlawful state action. View "In re B.Y." on Justia Law

Defendant was charged with eleven counts related to his alleged sexual abuse of C.E. The State requested that a magistrate bind Defendant over for trial. After a hearing, the magistrate concluded that the evidence was so contradictory, inconsistent, and unbelievable that she need not “give credence” to C.E.’s testimony. Because the case depended “solely on the testimony of [C.E.]”, the magistrate granted Defendant’s motion to dismiss the charges, finding that the prosecution failed to present sufficient evidence to support a reasonable belief that Defendant committed the crimes charged. The First Circuit reversed the magistrate’s decision, holding (1) the magistrate exceeded her discretion in disregarding C.E.’s testimony because there was at least a reasonable inference from the evidence that C.E. was telling the truth; and (2) the magistrate exceeded her discretion in refusing to bind Defendant over for trial because C.E.’s testimony described daily sexual abuse over a four-year period. View "State v. Schmidt" on Justia Law