Justia Utah Supreme Court Opinion Summaries

Kelly Colvin was killed in an automobile accident while returning to Utah from a work project in Maryland. The accident occurred when Colvin was a passenger in a vehicle driven by his coworker, Joseph Giguere. Colvin’s widow and son sued Giguere, claiming that Colvin’s death was proximately caused by Giguere’s negligent driving. Giguere moved for summary judgment, asserting that the exclusive remedy provision of the Workers’ Compensation Act barred this suit because the accident occurred in the course of his and Colvin’s employment. The district court agreed and granted Giguere’s motion for summary judgment. The Supreme Court affirmed, holding that because the accident occurred while Colvin and Giguere were carrying out a special errand for their employer, this action was barred under the Act’s exclusive remedy provision. View "Colvin v. Giguere" on Justia Law

The trustee of the United Effort Plan Trust filed a complaint against the City of Hildale and the Twin City Water Authority (TCWA) (together, Appellants) to compel the subdivision of certain parcels of Trust property located within the City’s boundaries. Because Appellants failed to appear or answer the complaint, the district court entered default judgment against them. Thereafter, Appellants filed a Utah R. Civ. P. 60(b) motion to set aside the judgment. While the motion was pending, Appellants filed a direct appeal from the default judgment. The district court denied Appellants’ Rule 60(b) motion, and Appellants did not appeal the denial. The Supreme Court subsequently dismissed Appellants’ direct appeal from the default judgment, holding that the direct appeal was the incorrect vehicle for relief because it relied exclusively on Rule 60(b) arguments made to the district court in the postjudgment motion and disposed of in the unappealed order. View "Wisan v. City of Hildale" on Justia Law

Petitioner was convicted of aggravated murder and sentenced to death. The Supreme Court affirmed the conviction and sentence. Petitioner subsequently filed a petition for postconviction relief, alleging that his counsel provided ineffective assistance at trial. The postconviction court granted summary judgment in favor of the State. Petitioner filed a notice of appeal in his postconviction proceedings and then filed a Utah R. Civ. P. 60(b) motion to set aside the postconviction court’s final judgment. The postconviction court denied the motion. The Supreme Court consolidated the appeals and affirmed the postconviction court’s grant of summary judgment and denial of Rule 60(b) relief, holding (1) Petitioner failed to raise a genuine issue of material fact for each of his ineffective assistance of counsel claims; and (2) the postconviction court did not abuse its discretion when it denied Petitioner’s motion for relief from judgment pursuant to Rule 60(b). View "Honie v. State" on Justia Law

Defendant pled guilty to unlawful sexual conduct with a minor. Defendant later moved to withdraw his guilty plea based upon ineffective assistance of counsel and a violation of Utah R. Crim. P. 11, arguing that his plea was not knowing or voluntary because neither his defense counsel nor the trial court informed him that his guilty plea carried with it the requirement that Defendant register on the state’s sex offender registry. The district court denied Defendant’s motion to withdraw, concluding that neither defense counsel nor the district court had an obligation to inform him of the registration requirement because the registration requirement was a collateral consequence of the guilty plea. The Supreme Court affirmed, holding that the requirement to register as a sex offender is properly classified as a collateral consequence of a defendant’s guilty plea, and therefore, neither defense counsel nor the trial court in this case was constitutionally obligated to inform Defendant of the registration requirement before his guilty plea was accepted as knowing and voluntary. View "State v. Trotter" on Justia Law

After a jury trial, Frank and Joan Steed, husband and wife, were each convicted of three counts of failure to file a proper tax return and one count of engaging in a pattern of unlawful activity. The failure-to-file statute requires proof that a defendant failed to file with one of three specific intents. The Steeds moved to arrest the judgment largely on the same grounds upon which they relied in a previously denied motion to dismiss. Specifically, the Steeds contended that the State failed to provide sufficient evidence of two of the three specific intent alternatives. Ultimately, the trial court submitted only the two contested intent alternatives to the jury and excluded the remaining intent alternative. The Supreme Court reversed the Steeds’ convictions, holding (1) the State presented insufficient evidence of the two contested intent alternatives; (2) because the court excluded the single supported intent alternative and submitted the two unsupported intent alternatives to the jury, there was insufficient evidence to support the verdicts; and (3) because the pattern counts were contingent on the failure-to-file convictions, the pattern counts, along with the failure-to-file convictions, must be reversed. View "State v. Steed" on Justia Law

After a jury trial, Appellant was convicted of murder and child abuse for the death of her two-year-old son, Alex. Appellant appealed her convictions on several grounds. The Supreme Court affirmed, holding (1) a preponderance of the evidence is required to admit evidence of prior bad acts, and the trial court did not abuse its discretion in admitting evidence of prior child abuse under Utah R. Evid. 404(b); (2) Appellant’s defense counsel was not ineffective for, among other things, deciding not to introduce expert testimony regarding Battered Woman’s Syndrome because the trial strategy he selected was objectively reasonable; and (3) there was no cumulative error. View "State v. Lucero" on Justia Law

Energy Claims Limited (ECL), a British Virginia Island company, was the assignee of certain claims of Eneco, Inc. (Eneco), a now defunct Utah corporation. ECL filed suit in Utah district court, asserting Eneco’s claims against Eneco’s former directors, Catalyst Investment Group Limited (Catalyst), Timothy Roberts, and ARM Asset-Backed Securities, S.A. (ARM). All defendants resided, or had their principal place of business, outside of Utah. The district court (1) dismissed ECL’s claims against the former directors, Catalyst, and Roberts on the basis of forum non conveniens; and (2) dismissed the claims against ARM for improper venue based on a forum selection clause. The court of appeals affirmed. The Supreme Court reversed after declining ECL’s invitation to adopt a choice-of-law inquiry as a threshold to its forum non conveniens analysis, holding that the court of appeals erred in affirming dismissal of ECL’s claims against Defendants on the basis of forum non conveniens and on the basis of improper venue. Remanded. View "Energy Claims Ltd. v. Catalyst Inv. Group Ltd." on Justia Law

This action concerned the sale of certain property to Plaintiffs. The property was sold by Robert Rood, who, together with his company Level One Capital Partners, LLC, originated loans funded by Southern Management Corporation Retirement Trust (SMCRT). In 2006, Level One originated a loan to Thomas Gramuglia, which was secured by a trust deed for property Gramuglia owned in Park City. Gramuglia later sold the property to Plaintiffs. At the time of the purchase, Plaintiffs did not know the beneficial interest under the trust deed had been assigned to SMCRT. After SMCRT gave notice of its intent to foreclose on the property, Plaintiffs sued SMCRT. The district court determined (1) the trust deed encumbering the Plaintiffs’ property in Park City was invalid, (2) SMCRT had slandered Plaintiffs’ title, (3) SMCRT was liable for damages, and (4) Plaintiffs were entitled to recover their attorney fees, and a portion of those fees should be trebled. The Supreme Court (1) affirmed the district court’s grant of summary judgment and the majority of its award of damages; but (2) reversed the court’s grant of treble attorney fees, holding that the court erred when it concluded that Utah Code 57-1-38(3) permits the trebling of attorney fees. View "Dillon v. S. Mgmt. Corp. Ret. Trust" on Justia Law

After a jury trial, Defendant was convicted of aggravated murder, desecration of a body, kidnapping, and aggravated kidnapping. Defendant was sentenced to life without parole for his murder conviction. Defendant appealed, arguing, among other things, that it was error for his case to be tried in Cache County with Box Elder County jurors. The Supreme Court affirmed Defendant’s conviction of and sentence for aggravated murder and desecration of a body but reversed and vacated his kidnapping and aggravated kidnapping convictions, holding (1) the trial judge did not abuse his discretion in deciding to hold the trial in Cache County with a jury consisting of residents of neighboring Box Elder County; and (2) because Defendant’s kidnapping and aggravating kidnapping convictions merged, the kidnapping conviction should have been vacated, and Defendant’s aggravated kidnapping conviction should have merged with his aggravated murder conviction. View "State v. Nielsen" on Justia Law

Defendant pled guilty to criminally negligent automobile homicide and driving under the influence of alcohol, reserving his right to challenge the denial of his motion to suppress evidence obtained through a blood draw. Defendant’s blood was drawn after the police were issued eWarrants through the Utah Criminal Justice Information System. On appeal, Defendant argued that because the affidavits submitted by the police in order to obtain the warrants were not supported by an oath or affirmation, as required by both the Utah and United State constitutions, the warrants were unconstitutional. The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress, holding that the affidavits comported with the historical understanding of what constitutes a constitutionally valid “affirmation,” and therefore, the affidavits were constitutionally sufficient to support the issuance of the warrants in this case. View "State v. Gutierrez-Perez" on Justia Law