Justia Utah Supreme Court Opinion Summaries

Robert Baird sought a civil stalking injunction against his mother, Gloria Baird, because Gloria contacted him almost every day. The district court granted a three-year injunction, determining that Gloria’s nearly daily phone calls to Robert were causing Robert emotional distress. Gloria appealed, arguing that the district court misinterpreted Utah’s Stalking Statute because it entered the injunction based on its finding that Gloria’s conduct was causing Robert emotional distress without finding that her conduct would have caused emotional distress to a reasonable person in Robert’s circumstances. The Supreme Court vacated the stalking injunction, holding (1) the Stalking Statute required the district court to determine whether Gloria’s conduct would cause a reasonable person in Robert’s circumstances emotional distress; and (2) the statutory definition of emotional distress means mental or psychological suffering, and there is no requirement that the emotional distress arise from outrageous and intolerable conduct by the respondent. View "Baird v. Baird" on Justia Law

The State charged Defendant with various crimes, including aggravated burglary and aggravated assault. After the jury was empaneled and sworn and on the second day of trial, the trial judge announced that she was recusing herself and declaring a mistrial. The case was subsequently reassigned for retrial under a new judge. Defendant moved to dismiss the charges against him on the grounds of double jeopardy. The trial court denied the motion, concluding that the mistrial did not act as an acquittal because the mistrial was legally necessary. The Supreme Court reversed, holding (1) the burden to create a record for and sufficiently justify the mistrial fell on the trial court and the State, and, in this case, the legal necessity for a mistrial was not established on the record; and (2) Utah’s constitutional protections against double jeopardy precluded a second trial under such circumstances. View "State v. Manatau" on Justia Law

Appellant was convicted of lewdness involving a child and sexual exploitation of a minor by distribution of child pornography for dropping his pants in front of two young girls, exposing a toddler-sized diaper he was wearing, and in distributing a flyer containing images of children and adolescents wearing diapers. On appeal, Appellant argued, among other things, that the evidence was insufficient to sustain his convictions. The Supreme Court agreed and reversed, holding that, while Appellant’s conduct was deplorable and socially inappropriate, it did not fall to the level of criminal lewdness or sexual exploitation under the criminal definition of those terms as clarified in this opinion. View "State v. Bagnes" on Justia Law

Plaintiffs, employees of Kane County Hospital, sued various parties, including Utah Retirement Systems (URS), based on the Hospital’s alleged failure to adequately fund their retirement benefits as required by the Utah State Retirement and Insurance Benefit Act (“Act”). Before Plaintiffs filed their lawsuit, URS initiated an administrative proceeding against the Hospital, pursuant to the Act, seeking recovery of unpaid benefit contributions for Hospital employees. The district court dismissed Plaintiffs’ claims for lack of jurisdiction because Plaintiffs had not exhausted their administrative remedies. The court of appeals reversed and ordered that the case be stayed pending resolution of URS’s administrative action against the Hospital, concluding that it was impossible to ascertain which claims were subject to the exhaustion requirement until the pending administrative action was resolved. The Supreme Court reversed, holding that it lacked jurisdiction over Plaintiffs’ claims based on their failure to exhaust their administrative remedies because all of the claims fell within the scope of the Act and none of the exceptions to exhaustion applied. View "Ramsay v. Kane County Human Res. Special Serv. Dist." on Justia Law

Christopher Carlton, a Pennsylvania resident, was in a relationship with Shalanda Brown, who was pregnant with Carlton’s child. Unbeknownst to Carlton, Brown traveled to Utah, where she gave birth to a baby girl and relinquished her parental rights to Adoption Center of Choice, Inc. Because no putative father was registered with respect to the child, Adoption Center commenced and adoption proceedings for the child, which were later finalized. Brown, however, had informed Carlton that the child had died. After Brown subsequently told Carlton that the baby was still alive and had been given up for adoption, Carlton filed an amended petition to establish paternity challenging the constitutionality of the Utah Adoption Act and the extent of the rights it affords to putative fathers who wish to contest adoptions in Utah. The district court dismissed Carlton’s petition based on a lack of standing. The Supreme Court reversed in part, holding that the district court erred in (1) denying Carlton leave to amend his petition to cure standing defects to assert the constitutional claims, and thereby, in dismissing Carlton's constitutional claims; and (2) dismissing Carlton’s claim for intentional infliction of emotional distress. Remanded. View "Carlton v. Brown" on Justia Law

The Utah Occupational Safety and Health Division (UOSH) cited and fined Hughes General Contractors, which oversaw a construction project involving over 100 subcontractors, for a subcontractor’s violation on the project. In determining that Hughes was responsible for safety conditions for the subcontractor’s employees, the UOSH invoked the multi-employer worksite doctrine, which makes a general contractor responsible for the occupational safety of all workers on a worksite, including those who are not the contractor’s employees. Both an administrative law judge and the Labor Commission’s Appeals Board upheld the citation and the multi-employer worksite doctrine, which federal OSHA regulations have adopted and federal courts have upheld. The Supreme Court reversed the citation and penalty, holding (1) the multi-employer worksite doctrine is incompatible with the governing Utah statute, Utah Code 34A-6-201(1; (2) the responsibility for ensuring occupational safety under the governing statute is limited to an employer’s responsibility to its employees; and (3) because Hughes was not an employer of the workers in question in this case, Hughes was improperly cited and sanctioned. View "Hughes Gen. Contractors, Inc. v. Utah Labor Comm’n" on Justia Law

Wade Marinoni was employed as a first-response emergency medical technician (EMT) for Carbon County. After an incident involving an immediate transport of a patient having a heart attack, Marinoni was fired for failing to immediately respond to the transport request. Marinoni applied for and was awarded unemployment benefits. The ALJ affirmed, finding that Marinoni had acted in good faith according to his understanding of his employer's protocol. The Workforce Board of Appeals affirmed, concluding that Carbon County did not meet its burden to demonstrate just cause for termination. The Supreme Court affirmed the court of appeals' ultimate determination upholding the award of unemployment benefits, holding (1) the court of appeals erred in declining to consider in its legal analysis the uncontested fact that Marinoni knew the patient was having a heart attack; but (2) the Board's legal conclusions regarding culpability were within the scope of the deference granted to the Board's decision. View "Carbon County v. Workforce Appeals Bd." on Justia Law

The Church of Jesus Christ of Latter-day Saints (the Church) established a help line, which Church clergy could call when they became aware of possible abuse. Plaintiff filed a personal injury suit against the Church, claiming that her Church bishop negligently failed to report her abuse as required by the reporting statute and that the Church was vicariously liable for the bishop’s negligent conduct. The district court granted summary judgment in favor of the Church, concluding that the Church was immune from suit under the First Amendment. The Supreme Court affirmed but on different grounds, holding (1) the Church and its clergy did not voluntarily assume a duty to aid abuse victims by virtue of its help line because a clergy member’s failure to use the help line does not increase a victim’s risk of harm; and (2) the imposition of a duty based solely on the creation of the help line would be contrary to public policy because it would discourage organizations from providing services that ultimately benefit victims of abuse. View "MacGregor v. Walker" on Justia Law

After a jury trial, Defendant was convicted of sexual battery, a misdemeanor. Before trial, the district court ruled that evidence of other sexual misconduct allegations against Defendant was inadmissible. However, during redirect examination of an investigating detective, the prosecutor elicited testimony about other allegations of sexual misconduct against Defendant, which was classified as Utah R. Civ. P. 404(b) evidence. A panel majority of the court of appeals reversed and remanded for a new trial after refusing to apply the presumption of regularity in favor of the State, holding that the district court plainly erred and counsel rendered ineffective assistance in allowing the Rule 404(b) evidence. The Supreme Court reversed without addressing the State’s argument that a gap in the record of a criminal trial should always be interpreted in favor of the State, holding that Defendant’s trial counsel was not ineffective in referencing and admitting the Rule 404(b) evidence, and the district court did not commit plain error in allowing the evidence to be presented. Remanded. View "State v. Bedell" on Justia Law

Petitioner was working as a park ranger for Utah State Parks and Recreation when he suffered pain in his lower back after losing then regaining his balance on a boat dock while preparing to go on boating patrol. The Utah Labor Commission denied Petitioner's claim for benefits, concluding that the accident had aggravated a preexisting lower back condition and but that the unexpected wave that caused Petitioner to slightly lose his balance was not the legal cause of Petitioner's injury. The court of appeals affirmed. The Supreme Court upheld the court of appeals' ultimate decision to deny Petitioner compensation benefits; holding (1) the court of appeals erred in applying an abuse of discretion standard of review to the Commission's decision; but (2) even under a nondeferential standard of review, Petitioner failed to establish that his boat accident, rather than his preexisting back condition, was the legal cause of his injury.View "Murray v. Utah Labor Comm'n" on Justia Law