Justia Utah Supreme Court Opinion Summaries

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

Appellant was convicted of two counts of aggravated murder and related crimes. The Supreme Court affirmed. Thereafter, Appellant filed a petition for relief under the Post-Conviction Remedies Act (PCRA), claiming that newly discovered evidence in the form of testimony from two new witnesses would exonerate him and that the State violated his due process rights by knowingly introducing perjured testimony and fabricating evidence at trial. The district court dismissed Appellant’s PCRA claims. The Supreme Court affirmed, holding (1) because Appellant failed to demonstrate that no reasonable jury could enter a judgment of conviction in light of the new testimony, Appellant’s newly discovered evidence claims failed on their merits; (2) Appellant’s due process claims were procedurally barred because they could have been but were not brought at trial or on appeal; and (3) the district court did not abuse its discretion in denying Appellant’s motions for discovery and to amend his PCRA pleadings. View "Pinder v. State" on Justia Law

In this personal injury action arising out of an automobile accident, Robert and Terri Zeller filed a complaint against Charlotte Nixon alleging claims for negligence and loss of consortium. The Zellers submitted their claims for arbitration under Utah Code 31A-22-321, which provides that the election of arbitration stands unless a notice of rescission is filed within ninety days. After the ninety-day rescission period had passed, the Zellers moved to amend their complaint to add a claim for negligent entrustment against Nixon & Nixon, Inc. Nixon opposed the motion to amend and filed a motion to compel arbitration. The district court denied the motion to compel arbitration, concluding that the Zellers were justified in seeking the amendment, thus freeing the Zellers of the statutory limitations on their claims against Nixon and allowing their claims to proceed against Nixon & Nixon. The Supreme Court (1) reversed as to the claims against Nixon, as those claims were irretrievably subject to arbitration given the Zellers’ failure to rescind their election of arbitration within ninety days; and (2) affirmed as to the claims against Nixon & Nixon, holding that the Zellers’ earlier election of arbitration as to their claim against Nixon did not encompass their subsequent claim against the corporation. View "Zeller v. Nixon" on Justia Law