Justia Utah Supreme Court Opinion Summaries

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

Orlando Millenia (Plaintiff), the lender on a multi-million dollar real estate transaction, filed this suit alleging that United Title Services of Utah, Inc. breached its fiduciary duty as an escrow agent in the property transaction. In addition, Plaintiff asserted claims for vicarious liability against Stewart Title Insurance Co. and First American Title Insurance Co. under Utah Code 31A-23a-407, a provision that Plaintiff viewed as imposing vicarious liability on Stewart and First American for United Title’s actions as escrow agent. The district court granted summary judgment in favor of Defendants. The Supreme Court reversed, holding (1) Plaintiff stated a claim for breach of fiduciary duty that survived Defendants’ motions for summary judgment; and (2) Plaintiff successfully stated a claim for vicarious liability under section 407. View "Orlando Millenia, LC v. United Title Servs. of Utah, Inc." on Justia Law

Defendant was charged with aggravated murder, child kidnapping, and rape of a child. The case was assigned to Judge Kouris. Two weeks before the preliminary hearing, defense counsel filed a petition to evaluate Defendant’s competency to stand trial. Judge Kouris was scheduled to preside over Defendant’s competency evaluation. Defendant filed a motion to transfer adjudication of the competency petition to another judge, arguing that his competency evaluation must be adjudicated by a different judge because Judge Kouris had sat as magistrate in the case. The district court denied the motion to transfer. Defendant then moved to disqualify Judge Koruis, arguing that the judge created an appearance of bias. The district court denied the motion. The Supreme Court affirmed, holding (1) the disqualification issue became moot when Judge Kouris was transferred to a different court docket, causing this case to be reassigned during the pendency of this appeal; and (2) a district court judge retains the authority to act as both a magistrate and a judge in the same criminal case. View "State v. Black" on Justia Law

This case involved a lease agreement between Greyhound Lines, Inc., the lessee, and Utah Transit Authority (UTA), the lessor, for a section of UTA’s intermodal transportation facility (intermodal hub). The insurance procurement provision of the lease agreement required Greyhound to purchase commercial general liability insurance covering UTA. At issue was whether the provision required that this insurance cover UTA’s negligent acts. This litigation resulted from a Greyhound passenger’s fall from a concrete pedestrian ramp during a layover at the intermodal hub. UTA admitted negligence in not installing a handrail on the pedestrian ramp. UTA settled the injured passenger’s claim and requested that Greyhound reimburse it for the cost of the claim under the lease agreement. Greyhound refused. The district court entered judgment against Greyhound. The Supreme Court affirmed, holding (1) under Utah law, an agreement to procure insurance for the benefit of another is not subject to strict construction; (2) the district court did not err when it concluded that the injured passenger’s claim triggered Greyhound’s duty to procure insurance that covered UTA’s negligent acts; and (3) the district court did not abuse its discretion in awarding UTA’s attorney fees. View "Utah Transit Auth. v. Greyhound Lines, Inc." on Justia Law

Appellant pleaded guilty to first-degree murder in 1988. Appellant later filed a motion to withdraw his plea. The district court denied the motion on the merits. The Supreme Court affirmed. In 2014, Appellant filed a motion to reinstate his right to appeal under Utah R. App. P. 4(f), claiming that his counsel had rendered ineffective assistance in advising him to accept the plea. The district court concluded that the allegations did not satisfy the criteria set forth by rule 4(f). Appellant’s appeal was transferred to the court of appeals under Utah R. App. P. 42(a). Appellant argued that the appeal was not subject to transfer. The Supreme Court issued an order temporarily recalling the transfer of this appeal for the purpose of determining whether it was within the Court’s exclusive jurisdiction. The Supreme Court transferred this appeal back to the court of appeals, concluding that this appeal was not within the Court’s exclusive appellate jurisdiction because the decision from which Appellant’s appeal was brought only denied a postjudgment request to reinstate the right to appeal, and Appellant’s appeal of that decision did not constitute a direct challenge to his conviction. View "State v. Smith" on Justia Law

During a rainstorm a culvert under a state road became obstructed, causing water to back up on the side of the road. Utah Department of Transportation (UDOT) workers tried to unclog the culvert but were unsuccessful and subsequently left the scene. The pooled water eventually caused the road to collapse. That night, Plaintiffs’ vehicles careened into the chasm, injuring two people and killing a fifteen-year-old. Plaintiffs sued UDOT, alleging negligent maintenance of the road and the clogged culvert. The district court granted summary judgment for UDOT, concluding that it was immune under the Governmental Immunity Act. The Supreme Court reversed, holding that UDOT failed to meet its burden of establishing that there was no genuine issue of material fact and that it was entitled to judgment as a matter of law. View "Barneck v. Utah Dep’t of Transp." on Justia Law

Plaintiff filed a wrongful death suit related to her husband’s exposure to asbestos. Plaintiff served numerous defendants within within 120 days of filing in accordance with the service-of-process provisions of Utah R. Civ. P. 4(b) but did not serve defendant Kerr Corporation until five years later. Kerr filed a motion to dismiss on the grounds that it had not been timely served. The district court denied the motion. At issue in this appeal was Rule 4(b)’s provision that “where one defendant in a case is served, other defendants may be served at any time prior to trial.” The Supreme Court affirmed, holding that Plaintiff complied with Rule 4(b)’s service of process requirements because she served Kerr prior to trial and while previously served defendants remained parties to the action. View "St. Jeor v. Kerr Corp." on Justia Law

Law Firm represented an employee in a workers’ compensation claim. Under a settlement agreement, the employee received a disability payment, part of which was earmarked as attorney fees. Defendant also agreed to pay the employee’s medical bills, which included bills from the University of Utah Health Care (Hospital). Law Firm sought to secure additional attorney fees from Hospital and filed an action alleging that it was entitled under a “common fund” theory to recover a percentage of the payments Hospital had received as a result of Law Firm’s efforts in pursuing the employee’s claim. The district court dismissed the action, concluding that the issue was a matter for the Labor Commission. The court of appeals affirmed. Law Firm subsequently asserted a claim before the Labor Commission against Hospital, again arguing for a right to recover fees on a common fund theory. An administrative law judge (ALJ) dismissed the claim, concluding that Law Firm had received all the fees it was statutorily due. Thereafter, Law Firm filed a further attempt at a common fund claim in the district court. The district court dismissed the claim, concluding that further litigation of the matter was barred by the doctrine of issue preclusion. The Supreme Court affirmed, holding that the elements of the doctrine of issue preclusion were amply satisfied in this case. View "Davis & Sanchez, PLLC v. Univ. of Utah Health Care" on Justia Law

Plaintiff sued several entities she believed to be responsible for her husband’s death. As required by the Utah Health Care Malpractice Act, Plaintiff first presented her malpractice claims to a prelitigation panel. During the ensuing litigation, designated her expert witnesses. The district court struck the witnesses because Plaintiff’s attorney revealed confidential information about them about the proceedings before the panel. Plaintiff then named two additional expert witnesses. The district court struck the replacement experts because they were designated after the cutoff date established by the scheduling order. Because Plaintiff was then deprived of any experts to establish the necessary elements of her malpractice claim, the district court granted summary judgment in favor of Defendants. The Supreme Court reversed, holding that the district court (1) erred by striking the original experts without inquiring whether the confidential information revealed to them influenced their opinions; and (2) erred when it excluded the second set of witnesses because it applied the wrong rule when it sanctioned Plaintiff for violating the scheduling order, and moreover, the sanction of witness exclusion was not warranted in this case. View "Coroles v. State" on Justia Law