Justia Utah Supreme Court Opinion Summaries

Father and Mother conceived a child together in Pennsylvania. Due to their age difference, the sexual relationship between Mother and Father was prohibited by Pennsylvania criminal law. Mother placed the child for adoption in Utah. After Father became aware of the adoptive parents’ adoption petition he filed a motion to intervene in the Utah adoption proceedings. The district court denied the motion to intervene, citing Utah Code 78B-6-111, which forbids a biological father from challenging an adoption when his child was conceived as a result of conduct that “would constitute any sexual offense” described in the Utah Criminal Code. The Supreme Court reversed, holding that section 78B-6-111 does not apply in this case because the statute does not apply to sexual conduct lacking any jurisdiction nexus in Utah. View "In re Adoption of J.M.S." on Justia Law

Duane Serrano was injured in a car accident while driving a truck within the scope of his employment with Provo City. More than four years later, Serrano quit his job. Serrano subsequently applied for permanent total disability compensation under the Workers’ Compensation Act. On remand, an administrative law judge (ALJ) found that the preponderance of the evidence showed that Serrano was permanently and totally disabled as a result of his accident and awarded him permanent disability payments. The Utah Labor Commission affirmed. The Supreme Court affirmed, holding (1) Serrano proved the elements of a permanent total disability claim; (2) the ALJ did not abuse her discretion by initially denying Serrano’s claim but then awarding benefits after the Labor Commission instructed her to reconsider the evidence; and (3) award of benefits should not commence on the date that Serrano was deemed to be permanently and totally disabled because of the extraordinary delay in resolving Serrano’s claim. View "Provo City v. Utah Labor Comm’n" on Justia Law

Amy Sawyer was a special education teacher for the Jordan School District. When Sawyer received a failing score for her second Jordan Performance Appraisal System (JPAS) evaluation, Sawyer was informed that she would be required to pass a third JPAS evaluation to keep her job or that she could resign in order to avoid the third evaluation. Concerned that if she were terminated that she would not find future employment as a teacher, Sawyer elected to resign rather than submit to a third JPAS evaluation. The Department of Workforce Services (DWS) denied Sawyer’s application for unemployment benefits based upon its finding that Sawyer quit her job without good cause. An administrative law judge (ALJ) upheld DWS’s decision, and the Workforce Appeals Board affirmed. The Supreme Court reversed, holding (1) good cause to quit is a fact-like mixed question of law and fact reviewed deferentially; but (2) the ALJ and Appeals Board applied an incorrect legal standard to this mixed question. Remanded. View "Sawyer v. Dep’t of Workforce Servs." on Justia Law

Child was conceived in Colorado. Mother later traveled to Utah where she gave birth to Child and placed it for Adoption. Mother never told Father of her plans to come to Utah and to proceed with the adoption in Utah. After learning of Child’s birth in Utah, Father filed a petition to establish paternity in a Utah district court. The district court granted summary judgment for Mother and the adoption agency (collectively, Respondents), concluding that Utah Code 78B-6-122 required Father to affirmatively establishing paternity before acquiring any right to notice of an adoption proceeding, and because Father failed to follow these steps under Colorado law to establish paternity, Father forfeited any rights he may have had to contest the adoption under Utah law. The Supreme Court reversed, holding that section 78B-6-122 merely required Father to fulfill the requirements of Colorado law to protect his interests as a father, and because Father’s parental rights would have remained intact under Colorado law until he was given notice and an opportunity to be heard, his parental rights were likewise preserved under Utah law. View "Nevares v. M.L.S." on Justia Law

Since 1971, a monument displaying a representation of the Ten Commandments tablets has stood in a park owned by the City of Pleasant Grove. In 2003, Summum, a corporation sole and church, offered to donate and erect a “Seven Aphorisms” monument in the park that was similar to the Ten Commandments monument. The City declined Summum’s offer. After unsuccessfully suing in federal court, Summum sued in federal court. The United States Supreme Court concluded that the placement of a monument on public property was a form of government speech not regulated by the Free Speech Clause. Summum subsequently sued in state court, alleging that the City had violated the religious liberty clause of the state Constitution and seeking an injunction requiring the City to display the Seven Aphorisms monument. The district court granted summary judgment for the City. The Supreme Court affirmed, holding that the religious liberty clause of the Utah Constitution does not require the district court to force the City to permanently display the Seven Aphorisms monument because the neutrality test adopted in Soc’y of Separationists v. Whitehead to determine whether a government action amounts to an unconstitutional appropriation of public money for religious exercise does not apply in the context of public monuments. View "Summum v. Pleasant Grove City" on Justia Law

Appellees alleged claims for tortious interference with economic relations against Appellant. The tortious interference theories each rested on two separate allegations: first, that Appellant had interfered with Appellees’ economic relations through an improper means; and second, that Appellant had interfered with Appellees’ economic relations in pursuit of an improper purpose. The district court partially granted Appellant’s motion for summary judgment, concluding (1) there was no evidence that Appellant had interfered with Appellees’ economic relations through an improper means; but (2) Appellant was not entitled to summary judgment on Appellees’ tortious interference claims insofar as they were based on the allegation that Appellant had acted with an improper purpose. The Supreme Court reversed, hereby rejecting the improper-purpose rule, holding that, contrary to Leigh Furniture & Carpet Co. v. Isom, a claim for tortious interference may only succeed where the defendant has employed an improper means. View "Eldridge v. Johndrow" on Justia Law

After a jury trial, Defendant was convicted of first-degree rape. The Supreme Court reversed, holding (1) trial counsel was ineffective for failing to object to a jury instruction misstating the requirement of mens rea as applied to the elements of first-degree rape; and (2) the statutory standard for nonconsent under Utah Code 76-5-406 does not establish the sum and substance of all circumstances amounting to nonconsent but simply prescribes the circumstances in which the legislature forecloses a jury finding of consent as a matter of public policy. The Court also clarified and the standard for granting a defendant’s request for a victim’s medical records under Utah R. Crim. P. 14(b). View "State v. Barela" on Justia Law

These cases arose from the marriage dissolution of Charles Dahl and Kim Dahl. Kim appealed the Divorce action, alleging several claims of error, and also brought a separate action against certain defendants seeking a share of the assets of the Dahl Family Irrevocable Trust, which she claimed were marital property. The Supreme Court consolidated the two cases and remanded for further proceedings because the Trust should have been joined as a party to the Divorce action. The Court further held (1) as to the Trust, Utah law applies, the Trust is revocable as a matter of law, and Kim is entitled to withdraw her share of the marital property she contributed to the Trust as a settlor; and (2) in the Divorce action, the district court judge was not biased against Kim, the district court did not abuse its discretion in its evidentiary rulings or in declining to award Kim alimony, the judgment pertaining to the division of the marital property is affirmed in part and reversed and remanded in part, the district court did not abuse its discretion when it awarded Charles sole legal and physical custody of the parties’ children, and the court did not err in not ordering Charles to pay Kim’s attorney fees. View "Dahl v. Dahl" on Justia Law

Defendant entered a conditional guilty plea to five charges of sexual exploitation of a minor. The charges arose from the discovery of child pornography on Defendant’s laptop computer. Defendant appealed, challenging several of the district court’s pretrial rulings, many of them related to the propriety of law enforcement’s use of the Wyoming Toolkit, a computer program and database used to identify child pornography shared over the Internet with peer-to-peer (P2P) file sharing networks. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress the evidence of child pornography found on Defendant’s computer, as the government’s use of the Wyoming Toolkit to identify child pornography in files shared on a P2P network is not a search; (2) the district court did not abuse its discretion in denying Defendant’s motion to compel discovery of the Wyoming Toolkit; (3) the classifications created by Utah’s sexual exploitation of a minor statute are constitutional, and Defendant lacked standing to challenge the constitutionality of the statute’s purported disparate treatment of prosecutors and criminal defense attorneys; and (4) the district court did not abuse its discretion in denying Defendant’s motion in limine to exclude expert testimony related to the Wyoming Toolkit. View "State v. Roberts" on Justia Law

Anadarko Petroleum Corporation, which acquired Kerr-McGee Oil & Gas Onshore L.P. in 2006, operated oil and gas wells from 2008 to 2011 and filed severance tax returns during this period. The severance tax rate an owner of oil and gas interests must pay depends on the fair market value of the owner’s interest. At issue in this case was how the value of such an interest is to be calculated. In 2010, the Auditing Division of the Utah State Tax Commission issued notices to Anadarko and Kerr-McGee (collectively Anadarko) informing Anadarko of a deficiency in its 2009 severance tax and assessing additional taxes and interest, and informing Kerr-McGee that its claimed 2009 refund was being reduced. Anadarko filed a petition for determination with the Commission. At issue before the Commission was whether the Auditing Division had applied the correct tax rate. The Commission granted summary judgment for the Auditing Division. The Supreme Court reversed, holding that the Commission improperly disallowed deductions Anadarko made for tax-exempt federal, state, and Indian tribe royalty interests under the severance tax statute. Remanded. View "Anadarko Petroleum Corp. v. Utah State Tax Comm’n" on Justia Law