Justia Utah Supreme Court Opinion Summaries

Plaintiff, a student at Utah Valley State College (UVSC), was injured while practicing with the state-owned college’s ballroom dance team. Plaintiff sued UVSC, alleging negligence. The district court dismissed the lawsuit, concluding that, in accordance with the public duty doctrine, UVSC owed no duty of care to Plaintiff. The court of appeals reversed, concluding that the special relationship exception to the public duty doctrine applied to Plaintiff. The Supreme Court granted certiorari and reversed the district court, although for different reasons from those expressed by the court of appeals, holding that Plaintiff’s lawsuit was not based on a public duty, and therefore, the public duty doctrine did not bar Plaintiff’s negligence claim. View "Cope v. Utah Valley State College" on Justia Law

Defendant was convicted of five securities law violations and one count of maintaining a pattern of unlawful activity related to an investment scheme. The court of appeals reversed Defendant’s securities law convictions, concluding that her counsel rendered ineffective assistance by stipulating to a jury instruction that the court concluded impermissibly shifted the burden to Defendant and relieved the State of its burden to prove each element of an offense beyond a reasonable doubt. The Supreme Court reversed, holding that the jury instruction at issue was an accurate statement of Utah law and not an evidentiary presumption unlawfully shifting the burden of proof to the defense. Remanded. View "State v. Kelson" on Justia Law

In order to object to an adoption under the Utah Adoption Act, unwed biological fathers must not just assert and establish paternity but must also file a sworn affidavit attesting that they are able and willing to support their child. Unmarried mothers are not required to provide similar assurances about how they will care for and support a child. William Bolden, the putative father of J.S., tried to intervene in and object to the adoption of J.S. The district court barred Bolden from intervening because he failed to preserve his legal rights as a father by timely filing a paternity affidavit. Bolden appealed, arguing that the affidavit requirement is unconstitutional because, among other things, it discriminates against unmarried fathers. The Supreme Court affirmed the denial of Bolden’s motion to intervene in the adoption proceedings, holding that the affidavit requirement does not violate Bolden’s due process or equal protection rights, as (1) Bolden failed to establish an infringement of a fundamental right of substantive due process; and (2) the state’s interests in protecting children by facilitating the adoption process are substantially advanced by the statutory affidavit requirement. View "Bolden v. Doe" on Justia Law

In 2011, the Utah legislature passed S.B. 165, which altered the requirements for placing an initiative on the ballot. Appellants in this case were sponsors of a local initiative petition. After attempting, unsuccessfully, to place the initiative on the ballot, Appellants filed suit against the Lieutenant Governor and Salt Lake County Clerk (collectively, the State), seeking a declaration that two of the amended provisions of S.B. 165 violated the right to initiative and uniform operation of laws provisions of the Utah Constitution and the Free Speech Clause of the United States Constitution. The district court denied Appellants’ claims. The Supreme Court affirmed, holding that the challenged amendments do not violate the Utah Constitution’s guarantees of the right of the people to initiate legislation or the uniform operation of the law, and further, do not violate the federal First Amendment. View "Cook v. Bell" on Justia Law

Utah Code 76-10-503 criminalizes possession of a “dangerous weapon” by a restricted person. Defendant was convicted under section 76-10-503 for having a pocketknife among his personal belongings, which he carried with him in a shopping cart. On appeal, Defendant argued that his pocketknife did not qualify as a dangerous weapon under the statutory definition of "dangerous weapon" in subsection 76-10-501(6) because the statute permitted consideration only of a knife’s actual use, not its intended use. The court of appeals affirmed, holding (1) an object’s intended use may be considered in determining whether an object is a dangerous weapon; and (2) the evidence was sufficient to establish that Defendant’s knife was a dangerous weapon. The Supreme Court reversed the court of appeals and vacated Defendant’s conviction, holding (1) subsection 76-10-501(6) permits consideration only of how the object was actually used; and (2) therefore, the evidence presented at trial was insufficient to establish that the knife in Defendant’s shopping cart was a dangerous weapon as defined by statute. View "Salt Lake City v. Miles" on Justia Law

Defendant was charged with several crimes involving sexual conduct with a minor. L.N., the alleged victim on each charge, sought to intervene by filing a notice of a claim for restitution. The State filed a parallel request for restitution, seeking travel costs and lost wages incurred by L.N. and her mother to attend hearings. The district court granted Defendant’s motion to strike, holding (1) crime victims are not parties to criminal proceedings and thus lack standing to file requests for restitution; and (2) the travel expenses and lost wages incurred by L.N. and her mother fell beyond the scope of recoverable restitution. The Supreme Court affirmed, holding that a crime victim has standing to file a request for restitution, but the district court’s error in denying L.N.’s filing was harmless, as restitution is allowed only for the pecuniary damages that a victim could recover in a civil action arising out of the defendant’s criminal conduct. Thus, the restitution at issue in this case was not properly compensable. View "State v. Brown" on Justia Law

This case stemmed from the district court’s approval of the Utah Department of Financial Institutions’ (UDFI) seizure of America West Bank Members, L.C. (Bank) and the appointment of the Federal Deposit Insurance Corporation as receiver of the Bank. The Bank filed a complaint against the State, UDFI, and the director of UDFI (collectively, the State), alleging breach of contract, breach of the covenant of good faith and fair dealing, constitutional takings, and due process violations. The district court dismissed the Bank’s claims for lack of sufficient factual allegations under Utah R. Civ. P. 12(b)(6). The Supreme Court affirmed, holding (1) the district court did not err when it dismissed the Bank’s claims; and (2) the district court did not hold the Bank to a heightened pleading standard. View "America West Bank Members, L.C. v. State" on Justia Law

Lisa Allred alleged that she sustained second and third-degree burns as a result of a lithotripsy procedure performed by Dr. Ronald Saunders. Lisa and Marlin Allred brought a medical malpractice suit against American Fork Hospital and Dr. Saunders. During discovery, Plaintiffs sought production of Dr. Saunders’ credentialing file from the Hospital, as well as the Hospital’s internal incident file concerning the lithotripsy procedure. The Hospital objected, asserting that the peer-review and care-review privileges protected the requested files from discovery. The district court (1) ruled that Dr. Saunders’ credentialing file was not privileged and ordered the Hospital to produce it; and (2) ordered the Hospital to produce the incident file for in camera review for the trial court to determine whether the documents were privileged. The Hospital and Dr. Saunders sought review. The Supreme Court (1) held Utah R. Civ. P. 26 creates an evidentiary privilege and remanded the matter for consideration of whether the items contained in Dr. Saunders’ credentialing file and the Hospital’s incident file were privileged from discovery under the amended Rule 26; and (2) held that the district court may undertake in camera review of any questionably-withheld material. View "Allred v. Saunders" on Justia Law

Defendant was charged with one count of aggravated sexual assault and two counts of domestic violence in the presence of a minor arising out of his attack on his wife in the presence of the parties’ four-year-old daughter. During voir dire, defense counsel used all five of his peremptory challenges on female members of the venire. The prosecution objected, and because Defendant failed to give nondiscriminatory explanations for two of the strikes, the trial court reinstated those two jurors. The court, however, did not restore the two peremptory challenges Defendant used to strike the jurors. The court of appeals affirmed, concluding that Defendant had not shown he was actually prejudiced by his counsel’s allegedly deficient performance or by the trial court’s alleged errors. the Supreme Court affirmed, holding (1) Defendant failed to show that any prejudice arose from any arguable deficiency in his counsel’s performance or that there was a basis for a presumption of prejudice; and (2) Defendant failed to establish the elements of plain error in regard to the trial court’s decision to reinstate the two jurors and its failure to sua sponte restore the peremptory challenges used to strike them. View "State v. Sessions" on Justia Law

Plaintiffs filed a medical malpractice action against Defendant, and the claims brought by one of the plaintiffs were referred to arbitration. After an arbitration panel issued its decision but prior to the district court confirming that ruling and disposing of the remaining claims, Plaintiffs appealed. After the district court’s subsequent ruling, the Supreme Court dismissed as premature Plaintiffs’ appeal. More than sixty days after entry of the judgment, Plaintiffs filed a Utah R. Civ. P. 60(b) motion seeking to reissue the judgment based on the presumption that the district court lacked jurisdiction to enter its previous judgment because it had been divested of jurisdiction by Plaintiffs’ premature notice of appeal. The district court agreed and reissued the judgment, purporting to “amend” the judgment, without substantively altering the original decision. Plaintiffs then filed another notice of appeal. The Supreme Court dismissed the appeal, holding that the district court had jurisdiction to issue the original judgment, and because Plaintiffs failed to timely appeal that judgment, the Supreme Court lacked jurisdiction to address any challenge to the merits. View "Garver v. Rosenberg" on Justia Law