Justia Utah Supreme Court Opinion Summaries

At issue in this case was the applicability of the “attenuation” exception to the exclusionary rule to a fact pattern involving an unlawful detention leading to the discovery of an arrest warrant followed by a search incident to arrest. Defendant in this case entered a conditional plea to drug-related charges, reserving the right to appeal the denial of his motions to suppress and reconsider. The court of appeals affirmed under the attenuation exception to the exclusionary rule. After noting that the lower courts are in “disarray” in their application of the attenuation doctrine to the outstanding warrant scenario and the lack of direction from the U.S. Supreme Court on the matter, the Supreme Court concluded (1) the attenuation exception is limited to cases involving intervening acts of a defendant’s free will, as in a confession or consent to search; and (2) because this case involved no independent act of a defendant’s free will, the attenuation doctrine was not implicated, and Defendant was entitled to suppression of the evidence secured in the search incident to his arrest. View "State v. Strieff" on Justia Law

David Ragsdale pleaded guilty to aggravated murder for shooting and killing his wife. Ragsdale committed the murder while under the influence of medications prescribed to him by Nurse Practitioner Trina West. The Ragsdales’ children, through their conservator, filed a negligence action against Nurse West and against Dr. Hugo Rodier, the consulting physician for Nurse West. In a previous case, the Court reversed the dismissal of the children’s tort suit against Nurse West. In this case, the Court reviewed the district court’s dismissal of the children’s claim against Dr. Rodier. At issue before the Supreme Court was whether Dr. Rodier had a duty to consult directly with Nurse West as to any individual prescription of controlled substances she wrote for David Ragsdale. The Supreme Court affirmed the dismissal of the claim against Ragdale, holding that nothing in the cited provisions of the Utah Nurse Practice Act imposed on Dr. Rodier a duty to consult on each of the individual prescription of a controlled substance. View "Jeffs v. Rodier" on Justia Law

After a jury trial, Defendant was found guilty of one count of murder and two counts of aggravated robbery. Upon sentencing Defendant, the trial court failed to comply with Utah R. Crim. P. 22(c)(1) by not informing Defendant of his right to appeal and of the thirty-day deadline for filing a notice of appeal. Over two years later, Defendant filed a motion seeking reinstatement of his right to appeal. The trial court denied the motion. The court of appeals reversed, concluding that because neither the trial court nor defense counsel informed Defendant of the thirty-day deadline, Defendant had a valid claim for reinstatement of the right to appeal. The Supreme Court reversed, holding that claims for reinstatement of the right to appeal are subject to harmless error review, and the court of appeals in this case erred by declining to apply harmless error analysis. Remanded. View "State v. Collins" on Justia Law

Utah Resources International, Inc. (URI) conducted a share consolidation transaction, and two minority shareholders dissented. URI petitioned the district court to determine the fair value of the shares. After the district court made its determination, URI filed an amended motion under Utah R. Civ. P. 62 to stay execution pending its appeal. The district court denied the amended motion. URI then filed an application for a stay with the Supreme Court under Utah R. App. P. 8, and while that application was pending, filed a separate appeal arguing that the district court improvidently denied its request to abate interest as a term of the stay under rules 62 and 60(b) of the Utah Rules of Civil Procedure. The Supreme Court denied URI’s request under rule 8. The Court then held that the district court did not err in refusing to rule on the abatement of interest issue, as district courts do not have authority to abate interest under rule 62, and URI never requested relief with the district court under rule 60(b). View "Utah Res. Int’l, Inc. v. Mark Techs. Corp." on Justia Law

Utah law provides that shareholders may dissent from certain corporate transactions and that the corporation must pay the dissenting shareholders “fair value” for their shares. Two minority shareholders of Utah Resources International, Inc. (URI) dissented from URI’s consummation of a share-consolidation transaction, but URI and the dissenters disagreed on the fair value of the dissenters’ shares. URI petitioned the district court to determine the fair value of the shares. The district court concluded that the fair value of the dissenters’ shares was more than two times the amount proposed by URI. The Supreme Court vacated the district court’s ruling, holding that the district court erred in disallowing four deductions from URI’s assets in determining the fair value of the dissenters’ shares in URI. Remanded. View "Utah Res. Int’l, Inc. v. Mark Techs. Corp." on Justia Law

Lane Myers Construction agreed to build two separate homes for Dick and Kym Kyker. The Kykers obtained a construction loan through National City Bank. The bank periodically paid Lane Myers on draw request forms that indicated that Lane Myers had no lien on the property. Because the Kykers failed to repay Lane Myers as promised, Lane Myers recorded a mechanic’s lien against the property. Lane Myers then filed suit seeking to enforce its lien. The district court granted summary judgment for the Kykers and National City, concluding that the draw requests substantially complied with the Utah Mechanics’ Lien Act in effectively waiving Lane Myers’ right to file a mechanic’s lien. The court of appeals reversed, concluding that the forms were not in substantial compliance with the Act because they failed to incorporate the four essential elements of the statutory “form” necessary to waive and release lien rights. The Supreme Court reversed and remanded, holding (1) the Act requires only a waiver and release signed by the lien claimant, and the “form” set forth in the Act is merely a safe harbor; and (2) genuine issues of material fact precluded summary judgment in this case. View "Lane Myers Constr., LLC v. Nat’l City Bank" on Justia Law

After Kenneth Vanderwerff’s death, Janetta Gardiner, Vanderwerff’s romantic partner for the three years before his death, filed a petition for a “judicial declaration of common law marriage.” The district court granted the declaration of marriage, and Gardiner was appointed as personal representative of the estate. Four of Vanderwerff’s cousins (Cousins) moved to set aside the marriage determination under Utah R. Civ. P. 60(b) and to intervene in the marriage action. The court granted intervention to the Cousins and set aside the declaration of marriage. Approximately two years after Gardiner’s petition was granted, the court dismissed the marriage case of its own accord for untimely service under Utah R. Civ. P. 4(b)(i). The Supreme Court reversed and reinstated the declaration of marriage, holding that the district court improperly set aside the declaration of marriage, granted intervention, and sua sponte dismissed the case for failure of service. View "Gardiner v. Vanderwerff" on Justia Law

After Plaintiff was terminated from his employment with NCR Corporation, Plaintiff brought suit, alleging thirteen causes of action. The district court dismissed eleven of Plaintiff’s claims pursuant to Utah R. Civ. P. 12(b)(6). The district court subsequently granted summary judgment to Defendant on Plaintiff’s remaining two claims for wrongful discharge in breach of an employment contract and breach of the implied covenant of good faith and fair dealing. Specifically, the court concluded that Plaintiff had failed to present evidence of an employment contract between the parties sufficient to overcome the presumption of at-will employment under Utah law. The court of appeals reversed the district court’s grant of summary judgment, concluding that NCR’s corporate policy manual could be read to create an implied contract rebutting the presumption that Plaintiff was an at-will employee. The Supreme Court reversed, holding that the court of appeals erred in determining that the language contained in NCR’s policy manual evidenced an intent to form an implied-in-fact contract sufficient to overcome the presumption of at-will employment. View "Tomlinson v. NCR Corp." on Justia Law

In 2014, the City of Draper passed and adopted a Resolution that levied a tax on property located within the Traverse Ridge Special Service District. Petitioners, five residents, collected certified voter signatures and asked the City to refer the Resolution to voters of the District. The City rejected the referendum petition, asserting that the tax levy was a nonreferable administrative action. Petitioners filed a petition for writ of extraordinary relief. The Supreme Court granted the relief sought, holding (1) the Resolution was properly referable to the voters because it was legislative in nature; and (2) the City’s constitutional challenge to the subjurisdictional referendum statute failed. View "Mawhinney v. Draper City" on Justia Law

In 2013, the Utah Public Service Commission (PSC) approved power purchase agreements between PacifiCorp and two small power producers. Under these agreements, PacifiCorp’s Rocky Mountain Power division would become obligated to purchase all power produced by the producers’ clean energy wind projects. Ellis-Hall Consultants, a competitor of the two small power producers, intervened in the PSC proceedings and subsequently appealed. The Supreme Court affirmed the PSC’s decision, holding (1) the power purchase agreements did not contravene the terms of an applicable regulatory tariff referred to as Schedule 38; (2) PacifiCorp did not engage in discrimination in its application of the terms of Schedule 38; and (3) the power purchase agreements were enforceable. View "Ellis-Hall Consultants, LLC v. Pub. Serv. Comm’n of Utah" on Justia Law