Justia Utah Supreme Court Opinion Summaries

In 1990, Chin Lee established a defined-benefit plan, which he converted in 1996 into a profit-sharing plan, both of which were qualified plans. Chin's sole proprietorship contributed funds to the Plan from 1990 to 1995. These funds were invested entirely in U.S. government obligations, the interest on which was tax-exempt. In their 2005 and 2006 tax filings, Chin and Yvonne Lee reported Plan distributions and claimed deductions for federal obligation interest that the Plan earned in those and in earlier years. The Utah State Tax Commission disallowed these deductions, concluding that the Lees' distributions from the Plan were not exempt from state taxation even though the Plan assets were invested solely in U.S. government obligations. The Supreme Court affirmed, holding that no portion of the Plan distributions was tax-exempt, as (1) the distributions from the Plan qualified for a tax exemption only if the Plan acted as a conduit, allowing the funds to retain their tax-exempt character after distribution; and (2) the Lees' qualified profit-sharing plan was a non-conduit entity, and thus, the funds did not retain their character as interest on U.S. obligations upon distribution to the Lees. Therefore, the distributions were fully taxable by Utah.View "Lee v. Utah State Tax Comm'n " on Justia Law

After a jury trial, Defendant, who was temporarily staying in the spare bedroom of the victim's father's house, was convicted of aggravated sexual abuse of a child. Defendant's conviction was based on the holding that he occupied a "position of special trust" in relation to the victim under Utah Code 76-5-404.1(4)(h). The district court and court of appeals both held Defendant was an "adult cohabitant" of a parent of the child, which was one of several positions specifically referenced in section 76-5-404.1(4)(h). The Supreme Court vacated Defendant's conviction and remanded, holding (1) the fact that a defendant occupies one of the positions listed in section 76-5-404.1(4)(h) is insufficient, standing alone, to establish the crime of aggravated sexual abuse of a child; (2) for the State to establish aggravated sexual abuse of a child under subsection 4(h), it must prove both that the defendant occupied a "position of authority" over the victim and that the position gave the defendant the ability to "exercise undue influence" over the victim; and (3) because the lower courts did not require the State to establish both elements, Defendant's conviction must be vacated.View "State v. Watkins" on Justia Law

The Metropolitan Water District of Salt Lake and Sandy (District) held an appurtenant easement that crossed Petitioner's residential property for the purpose of maintaining the Salt Lake Aqueduct. In 2009, Petitioner began making improvements to his backyard. In 2010, the District filed a complaint against Petitioner, seeking a declaratory judgment regarding its rights under the easement as well as injunctive relief requiring Petitioner to remove the existing improvements and enjoining him from making any additional improvements. The district court eventually entered default judgment against Petitioner on grounds that he failed to answer the complaint. Petitioner moved to set aside the default judgment, claiming mistake, inadvertence, surprise, or excusable neglect. The district court denied Petitioner's motion. The Supreme Court vacated the district court's denial of Petitioner's motion, holding (1) the court abused its discretion when it refused to set aside the default judgment without determining whether Petitioner knew that he had been served and was required to file an answer; and (2) Petitioner alleged a meritorious defense. Remanded.View "Metro. Water Dist. of Salt Lake & Sandy v. Sorf" on Justia Law

Child was removed from his home by the Division of Child and Family Services (DCFS). The juvenile court later terminated Mother's parental rights. Subsequently, both the child's grandmother and foster parents filed competing petitions to adopt Child. The juvenile court granted procedural priority to Foster Parents and dismissed Grandmother's petition without first holding a hearing to consider the merits of her petition. The Supreme Court reversed, holding (1) Grandmother preserved her claim to a hearing on the merits of her petition for relief; and (2) to properly evaluate the best interests of a child, courts must hold a hearing on the merits of competing adoption petitions, and accordingly, that the juvenile court erred in prioritizing Foster Parents' adoption petition and dismissing Grandmother's petition without first holding a hearing on its merits. Remanded.View "S.C. v. State" on Justia Law

The Utah Department of Transportation (UDOT) owned a piece of property on land adjacent to property owned by Plaintiff. Plaintiff filed a condemnation action, asserting a right to condemn a portion of UDOT's parcel to construct an access road to the development Plaintiff planned to build on its property. The district court granted summary judgment for UDOT, finding that the two parties' uses were incompatible because the detention pond on UDOT's property left no room for Schroeder's proposed road. Plaintiff appealed, challenging the district court's invocation of the more necessary public use doctrine and its refusal to allow an exception under the doctrine of compatible uses. The Supreme Court affirmed, holding that, absent any basis for a compatible use exception in this case, UDOT was entitled to judgment as a matter of law.View "Schroeder Invs., L.C. v. Edwards" on Justia Law

After a jury trial, Defendant was convicted of aggravated murder, aggravated robbery, and aggravated assault and sentenced to life without parole on the murder conviction. The Supreme Court affirmed, holding (1) Defendant failed to show that the prosecution's decision to charge him with aggravated murder and the district court's denial of his motion to amend the charge to murder violated his constitutional rights; (2) the aggravated murder statute is constitutional; and (3) the admission of victim impact testimony at Defendant's sentencing hearing did not violate constitutional prohibitions against cruel and unusual punishments, and therefore, defense counsel's failure to object to the testimony did not constitute ineffective assistance of counsel. View "State v. Mateos-Martinez" on Justia Law

Wolf Mountain and ASC Utah (ASCU) had been litigating their rights and responsibilities regarding development in a resort of several years. In 2011, the jury awarded ASCU $54,437,000 in damages. Wolf Mountain appealed. Meanwhile, in an effort to collect on the judgment, ASCU filed an application for writ of execution, listing Wolf Mountain's real and personal property. The court ordered Wolf Mountain's property to be sold, and after a public sale, ASCU purchased Wolf Mountain's interests in the claim asserted in this litigation. Wolf Mountain did not appeal from the writ of execution or any of the related orders or proceedings. ASCU then moved to dismiss Wolf Mountain's appeal as moot, arguing that because ASCU now owned Wolf Mountain's appellate rights, there was no longer a controversy. The Supreme Court affirmed the judgment, holding (1) ASCU did not acquire Wolf Mountain's appellate rights, and therefore, an actual controversy existed; and (2) Wolf Mountain failed to demonstrate that the district court erred or abused its discretion in any way.View "ASC Utah, Inc. v. Wolf Mountain Resorts, L.C." on Justia Law

In April 2002, Ogden City Police Officer Troy Burnett and another officer searched Plaintiff's motel room and found drugs and a firearm. Plaintiff pled guilty to two federal offenses, but the court of appeals overturned Plaintiff's conviction, concluding that the search violated the Fourth Amendment. Plaintiff subsequently brought a claim under 42 U.S.C. 1983 against Burnett in federal court based on the unreasonable search. Under the Tenth Circuit Court of Appeals' decisions at the time Plaintiff filed his complaint, approximately two years remained in the limitations period before his claim would become time-barred. A U.S. Supreme Court decision four days after the filing, however, overturned the Tenth Circuit's decisions and rendered Plaintiff's complaint approximately ten months late. The district court granted summary judgment to Burnett, concluding that, as a result of the U.S. Supreme Court's decision, Plaintiff's claim was time-barred and Plaintiff was not entitled to equitable tolling. The Tenth Circuit Court of Appeals subsequently certified a question to the Utah Supreme Court, which answered by holding that under Utah law, an intervening change in controlling law that extinguishes a previously timely cause of action does merit equitable tolling of the statute of limitations. View "Garza v. Burnett" on Justia Law

Melissa and Corey Waddoups sued Intermountain Health Care (IHC), among other defendants, alleging negligent credentialing after Dr. Barry Noorda performed several gynecological procedures on Melissa at an IHC facility. At issue in this case was Utah Code Ann. 78B-3-425, which prohibits a cause of action for negligent credentialing. Because Plaintiffs' negligent credentialing claim accrued before the enactment of the statute, the federal district court certified a question to the Supreme Court, asking whether section 78B-3-425 retroactively applied to bar negligent credentialing claims that arose prior to its enactment. The Supreme Court answered the question in the negative, holding that because section 78B-3-425 is a substantive amendment and contains no expression of retroactivity, it does not apply retroactively and therefore did not bar Plaintiffs' claim, which arose prior to its enactment. View "Waddoups v. Noorda" on Justia Law

Plaintiffs were the parents of a boy killed by a bear while camping with his parents in American Fork Canyon. Plaintiffs sued the State for negligence in failing to warn Plaintiffs of the dangerous condition created by the bear. The district court dismissed the claims under the permit exception to the Utah Governmental Immunity Act. The Supreme Court reversed. On remand, the district court again dismissed the case, concluding (1) the State owed no duty to Plaintiffs; and (2) even if the State did owe a duty to Plaintiffs, the natural condition exception to the Immunity Act precluded liability. The Supreme Court reversed, holding (1) the State owed Plaintiffs a duty because it undertook protective actions directed specifically at Plaintiffs as the next group to use the campsite; and (2) the natural condition exception did not immunize the state from liability because the bear was not a natural condition on the land pursuant to the Immunity Act. Remanded. View "Francis v. State" on Justia Law