Justia Utah Supreme Court Opinion Summaries

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

Plaintiff, an attorney, filed a complaint against his employer, alleging that he was terminated for refusing to violate the Utah Rules of Professional Conduct. Specifically, Plaintiff alleged that he was fired for refusing to break the law by complying the company’s ongoing violation of usury laws in numerous states. The district court dismissed the complaint, concluding that Plaintiff was an at-will employee and that his termination did not violate a clear and substantial public policy of the state. The Supreme Court affirmed, holding (1) the district court properly dismissed Plaintiff’s wrongful termination claim, where Plaintiff failed to invoke a clear and substantial public policy that would have prohibited his employer from terminating him, and where rule 1.13(b) of the Utah Rules of Professional Conduct does not reflect the type of public policy that prevents the termination of an at-will employee; and (2) the district court erred when it denied Plaintiff’s request for a hearing, but the error was harmless. View "Pang v. Int’l Document Servs." on Justia Law

Plaintiff, an attorney, filed a complaint against his employer, alleging that he was terminated for refusing to violate the Utah Rules of Professional Conduct. Specifically, Plaintiff alleged that he was fired for refusing to break the law by complying the company’s ongoing violation of usury laws in numerous states. The district court dismissed the complaint, concluding that Plaintiff was an at-will employee and that his termination did not violate a clear and substantial public policy of the state. The Supreme Court affirmed, holding (1) the district court properly dismissed Plaintiff’s wrongful termination claim, where Plaintiff failed to invoke a clear and substantial public policy that would have prohibited his employer from terminating him, and where rule 1.13(b) of the Utah Rules of Professional Conduct does not reflect the type of public policy that prevents the termination of an at-will employee; and (2) the district court erred when it denied Plaintiff’s request for a hearing, but the error was harmless. View "Pang v. Int’l Document Servs." on Justia Law

Utah County established an off-site work-release program for potentially dangerous inmates in its custody and screened each inmate before placing them with employers. Shawn Michael Leonard escaped while on the work-release program and assaulted Plaintiff near the Provo River Trail. Plaintiff survived, but her injuries were substantial. Plaintiff filed a negligence action against the County. The district court ruled in favor of the County, concluding that it did not owe a duty to Plaintiff and, alternatively, that the Utah Governmental Immunity Act barred all of Plaintiff’s claims. The Supreme Court affirmed the district court’s decision dismissing Plaintiff’s negligence claims against the County, holding (1) the County owed Plaintiff a duty of care because it took affirmative steps that created a risk of harm; but (2) the Governmental Immunity Act is not unconstitutional as applied in this case, where work-release programs are essential to the core governmental activity of housing and rehabilitating inmates, and therefore, governmental immunity barred Plaintiff’s claim. View "Scott v. Universal Indus. Sales" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated murder and one count of theft by receiving a stolen motor vehicle. Defendant was sentenced to life in prison without the possibility of parole on the aggravated murder counts. Defendant appealed, raising several claims of ineffective assistance of counsel. The Supreme Court granted Defendant’s motion for remand and stayed the appeal. After a hearing, the district court rejected all of Defendant’s claims. The Supreme Court affirmed Defendant’s convictions, holding that defense counsel either did not perform deficiently or that Defendant failed to show prejudice stemming from defense counsel’s alleged deficiencies. View "State v. Nelson" on Justia Law

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

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