Justia Utah Supreme Court Opinion Summaries

While employed with Employer, Employee agreed to arbitrate any disputes arising from his employment. Employee's employment was later terminated. Employee filed a charge of discrimination with the Utah Anti-Discrimination and Labor Division of the Utah Labor Commission (UALD), alleging that Employer discriminated against him, retaliated against him, and harassed him. The UALD dismissed Employee's discrimination claims. Employee appealed to the Utah Labor Commission. The district court subsequently granted Employer's motion to compel arbitration and ordered Employee to submit to arbitration. The Supreme Court vacated the order compelling arbitration, holding that the district court erred in compelling arbitration because the plain language of the arbitration clause in Employee's employment contract allowed him to pursue administrative remedies prior to submitting to arbitration.View "Zions Mgmt. Servs. v. Record" on Justia Law

Defendant confessed to helping Glenn Griffin commit murder. The State charged both Griffin and Defendant with the crime. The State prosecuted Griffin first and, concerned that Defendant would invoke his privilege against self incrimination and refuse to testify, offered Defendant use immunity. The district judge subsequently issued an order compelling Defendant to testify, but Defendant refused. Thereafter, the State charged Defendant with three counts of obstruction of justice. After a hearing, the magistrate judge refused to bind Defendant over for trial and dismissed the obstruction of justice charges. The court of appeals affirmed, finding that State had failed to present sufficient evidence of intent to obstruct. The Supreme Court reversed, holding that the evidence was sufficient to bind Defendant over for trial for obstruction of justice. Remanded.View "State v. Maughan" on Justia Law

Appellant entered into a contingency fee agreement with Appellee, an attorney, which provided that Appellee was entitled to one-third of Appellant's primary award. The underlying action resulted in a judgment in favor of Appellant. Thereafter, the district court awarded a supplemental attorney fees award to Appellant. Appellant paid Appellee one-third of he primary judgment but did not pay Appellee any portion of the supplemental attorney fees award. After Appellant did not give Appellee one-third of the attorney fees award, Appellee filed an attorney's lien against his asserted one-third share. The district court denied Appellee's lien. Appellee subsequently filed an seeking a declaration that he was entitled to one-third of Appellant's attorney fees award. The district court entered judgment in favor of Appellee. The Supreme Court affirmed, holding (1) the agreement was unambiguous; and (2) under the agreement's terms, Appellee was entitled to one-third of both the primary judgment and the court-awarded attorney fees.View "Redd v. Hill" on Justia Law

Legacy Resources, Inc. brought several claims against Liberty Pioneer Energy Source, Inc. The district court dismissed Legacy's breach of contract and trade secret claims on summary judgment, determining (1) Legacy violated the securities laws by acting as an unlicensed broker in recruiting investors on behalf of Liberty; and (2) Legacy's securities violations rendered its contract unenforceable under Utah Code 61-1-22(8). The Supreme Court affirmed in part and reversed in part, holding (1) the undisputed facts sustained the conclusion that Legacy acted as an unlicensed broker, which violation foreclosed the enforcement of one of its contracts; but (2) another of Legacy's contracts was not implicated by the securities violation, and thus the district court erred by granting summary judgment on Legacy's claim under that contract, along with its trade secret claim. View "Legacy Res., Inc. v. Liberty Pioneer Energy Source, Inc." on Justia Law

Plaintiff was injured at ShopKo Stores, Inc. when she sat on a display office chair and the chair collapsed. Plaintiff sued ShopKo for negligence. A jury found ShopKo negligent but awarded Plaintiff much less than she requested in damages. The court of appeals reversed and remanded for a new trial, concluding that the trial court erred in giving an instruction to the jury that it should apportion damages between those attributable to ShopKo's negligence and those attributable to Plaintiff's preexisting conditions. The court of appeals concluded that ShopKo was not entitled to the apportionment jury instruction because Plaintiff's preexisting conditions were asymptomatic on the date of the accident. The Supreme Court affirmed the court of appeals' grant of a new trial, holding (1) the court of appeals erred in taking a bright-line approach to analyzing preexisting conditions, which risks holding defendants liable for more damages than they proximately caused; but (2) the apportionment instruction was erroneous and prejudicial because ShopKo did not present evidence sufficient for the jury to apportion damages on a nonarbitrary basis. Remanded for a new trial.View "Harris v. ShopKo Stores, Inc." on Justia Law

Plaintiff sustained injuries when he tripped on an uneven section of sidewalk maintained by Salt Lake City. Plaintiff sued the City, alleging that the City negligently failed to maintain the sidewalk. After Plaintiff's case in chief, the City moved for a directed verdict, arguing that Plaintiff had not produced evidence that the City had adequate notice to remedy the sidewalk defect. The trial court granted the motion. The trial court subsequently granted Plaintiff's motion for a new trial, ruling that it had erred by granting the City's motion for a directed verdict because whether the City had sufficient notice to remedy the defect in the sidewalk was a question for the jury. After a retrial, the jury returned a verdict for Plaintiff. The Supreme Court affirmed, holding (1) the City in this case was not entitled to discretionary function immunity; (2) Plaintiff presented evidence at the second trial that the City had adequate notice of the sidewalk defect; and (3) the City's evidentiary arguments were either barred by the invited error doctrine or unsupported by the record. View "Kerr v. City of Salt Lake" on Justia Law

Plaintiffs, property owners in a development, filed a derivative suit against Defendants, the directors of the non-profit homeowners association that provided road maintenance and other services to the development, alleging that the directors favored their own properties in their allocation of road construction and maintenance funds. Instead of defending the suit on the merits, Plaintiffs appointed an independent committee to evaluate whether maintenance of the derivative suit was in the best interest of the nonprofit corporation pursuant to Utah Code 16-6a-612(4). Based on the committee's report, the district court dismissed the suit. The Supreme Court reversed, holding that the district court erred in concluding that the members of the committee, all of whom owned property allegedly receiving preferential treatment, were "independent" under section 612(4). Remanded to allow the district court to assess whether the directors were independent, applying the definition of independence clarified by the Court in this opinion.View "Hi-Country Prop. Rights Group v. Emmer" on Justia Law

In 2010, Plaintiff was negotiating the sale of three limited liability companies of which he was the sole shareholder. The companies were S Corporations. Plaintiff retained an Accounting Firm to advise him on his tax liability from the contemplated sale. Altaview Concrete, one of the companies, was named as the client. Jeffrey Bickel, a partner at the Accounting Firm, advised Plaintiff that he could restructure the deal to reduce his tax liability to $663,000. The buyer agreed to the restructuring proposals, and the sale closed. Later Bickel and the Accounting Firm (collectively, Defendants) discovered they had greatly underestimated Plaintiff's tax liability. Plaintiff filed a professional negligence claim in district court. The district court granted Defendants' motion for summary judgment, finding that Plaintiff's claim failed to satisfy the writing requirement of Utah Code 58-26-602, which provides that accountants are not liable to third parties unless the accountant identified in writing to the client that the professional services were intended to be relief upon by the third party. The Supreme Court reversed, holding that Defendants were liable to Plaintiff as a third party under section 602 because Defendants identified in writing that the professional services were intended to be relied upon by Plaintiff.View "Reynolds v. Bickel" on Justia Law

Capital Assets Financial Services, the owner of property within the City of Saratoga Springs, asked the city council to rezone its property from a low density to a medium density residential zone. The city council granted the request. A group of citizens submitted a petition to the City requesting that the site-specific rezoning be placed on the ballot as a referendum. The City granted the request. Capital Assets subsequently filed a complaint against the City requesting a declaration that the action of the city council was made through its administrative, and not legislative, power. The district court ruled in favor of Capital Assets, declaring that the site-specific zoning was administrative and thus not subject to referendum, and enjoining the City from placing the referendum on the ballot. Thereafter, the citizens' group filed a petition for an extraordinary writ. The Supreme Court granted the petition and directed the City to place the referendum on the ballot, holding that the site-specific rezone of Capital Assets' property was a legislative matter and thus subject to referendum. View "Krejci v. City of Saratoga Springs" on Justia Law

In 2002, Plaintiff, the owner of a car dealership, executed two vehicle contracts with Henry Day Ford to preorder two Ford GT40s (later renamed the GT). After Henry Day learned it would not be receiving GT40s in its allocation, it refunded Plaintiff's deposit. Plaintiff did not object. In 2004 and 2005, Henry Day learned it had been allocated three GTs. Plaintiff demanded that Henry Day sell him two GTs at the price specified under the contracts. Henry Day instead offered to sell Plaintiff one GT for a higher price. Plaintiff refused the offer and filed a complaint alleging breach of contract and unjust enrichment. The district court ruled in favor of Henry Day. The court of appeals reversed, holding (1) despite a latent ambiguity in the contracts regarding the identity of the vehicles to be sold, both parties intended that the contracts cover the vehicle now known as the Ford GT; and (2) Plaintiff did not intend to abandon the vehicle contracts. The Supreme Court affirmed, holding (1) the vehicle contracts contained a latent ambiguity, but the ambiguity did not excuse either party's performance under the contracts; and (2) the issue of whether Plaintiff abandoned his rights under the contracts required a remand for additional findings. Remanded.View "Watkins v. Henry Day Ford" on Justia Law