Justia Utah Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals concluding that Defendant, Gregory Miller, could be guilty of stalking Kendra, holding that the court of appeals did not err in interpreting the stalking statute and that there was sufficient evidence to sustain the conviction.A jury found Defendant guilty of stalking Kendra based on emails that Defendant sent to an attorney who represented Kendra and Kendra's then-employer. The trial court judge arrested the judgment, concluding that no reasonable jury could have convicted Defendant of stalking based on the emails. The court of appeals reversed. The Supreme Court affirmed, holding that the court of appeals (1) correctly interpreted the stalking statute; and (2) did not err in holding that there was sufficient evidence to permit a reasonable jury to find Defendant knew or should have known his conduct would cause a person in Kendra's circumstances emotional distress. View "State v. Miller" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating Defendant's convictions based on ineffective assistance of counsel, holding that errors in the proceedings below did not prejudice Defendant.In vacating Defendant's convictions the court of appeals concluded that trial counsel had been ineffective by failing to object to introduction and use of evidence about Defendant's silence while being arrested and by not objecting to the manslaughter jury instruction. The court ultimately concluded that Defendant was prejudiced by these instances of deficient performance. The Supreme Court reversed and reinstated the convictions vacated by the court of appeals, holding (1) trial counsel performed deficiently in failing to object to a certain jury instruction; and (2) assuming counsel was also deficient for not objecting to the State's use of Defendant's post-arrest, pre-Miranda silence against Defendant, Defendant failed to establish that there was a reasonable probability that the outcome of the trial would have been different without these errors. View "State v. Bonds" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court concluding that Pleasant Grover (City) had the power to enact a three-tiered "transportation utility fee" (TUF) but reversed the court's ruling that the TUF was actually a tax, holding that remand was required.The subject TUF charged local property owners a monthly fee corresponding to the "intensity" with which they used City roads, as determined by a study of user demand on the City's roadways, and the generated funds were to be used to repair and maintain city roadways only. At issue was whether the City had the authority to enact the TUF and whether the City properly characterized the TUF as a fee or if it was in fact a tax requiring the City to follow specific enactment procedures. The district court held that the TUF was actually a tax based on its purpose. The Supreme Court reversed in part, holding (1) the City acted within its discretion in enacting the TUF; but (2) the purpose of the TUF was characteristic of a fee because it was a specific charge for a specific purpose. View "Larson v. Pleasant Grove City" on Justia Law

The Supreme Court remanded this case in which the district court prohibited Father from encouraging his children to adopt the teachings of any religion without Mother's consent, holding that Father had a fundamental right to encourage his children in the practice of religion and that the district court's prohibition was not narrowly tailored to address the harms identified by the court.When they married, Father and Mother were both members of the Order, a polygamous religious community. Based on the parties' inability to agree on decisions regarding their four children, the district court granted sole legal custody to Mother and prohibited Father from encouraging the children to adopt the teachings of any religion. The Supreme Court remanded this case to the district court, holding (1) parents have a fundamental right to encourage their children in the practice of religion, and this right is not dependent upon legal custody; (2) strict scrutiny applies to this case; and (3) the district court's prohibition is not narrowly tailored to address the identified harms. View "Kingston v. Kingston" on Justia Law

In this real estate case, the Supreme Court affirmed the judgment of the district court dismissing this complaint brought by Rocky Mountain Hospitality, LLC (Seller) against Mountain Classic Real Estate, Inc. (Buyer) and awarded Buyer its attorney fees on appeal, holding that because Seller failed to release its interest in the deposit before filing its complaint it was barred from pursuing other remedies.Buyer entered into a contract with Seller to purchase a motel. The purchase price included an earnest money deposit. Buyer failed to purchase the motel. Seller brought this action seeking damages but failed to release its interest in the earnest money deposit before filing the complaint. The district court dismissed the complaint. The Supreme Court affirmed, holding (1) under the contract's default provision, Seller was obligated to release its interest in an earnest money deposit before filing a complaint if Seller wished to pursue a remedy other than liquidated damages; and (2) Seller was deemed to have elected to retain the deposit as liquidated damages and was barred from pursuing its claims. View "Rocky Mountain Hospitality v. Mountain Classic Real Estate, Inc." on Justia Law

The Supreme Court affirmed the order of the district court awarding Defendant an additional $9,000 in attorney fees and $162 in costs in a second appeal after the first appeal resulted in an award of attorney fees and costs for Defendant totaling $26,413, holding that there was no error and that the award of attorney fees was proper.Plaintiff sued for unlawful detainer, breach of lease, and unjust enrichment. The district court granted summary judgment for Defendant but denied Defendant's request for attorney fees. The court of appeals reversed the ruling on attorney fees. On remand, the district court awarded Defendant attorney fees and costs totaling $26,413. The court of appeals affirmed. On remand, the district court awarded Defendant additional attorney fees and costs. The Supreme Court affirmed and granted Defendant's request for attorney fees incurrent on appeal, holding that Defendant was properly awarded his attorney fees in the district court and that Defendant was entitled to reasonable attorney fees that he incurred in defending against this appeal. View "Gardiner v. Anderson" on Justia Law

The Supreme Court denied a motion for emergency relief and a petition for extraordinary writ in this election dispute, holding that the motion and petition failed to demonstrate that the relief Petitioners sought was timely requested and available.Petitioners filed a motion for emergency relief and an extraordinary writ seeking an order compelling the Lieutenant Governor to remove Joel Ferry's name from the ballot for the November 2022 general election. The Supreme Court denied both the motion and the petition, holding that the documentation accompanying the petition and motion strongly suggested that there would be inadequate time to alter the ballots before the mailing deadline even if the court ruled immediately. View "Utah Democratic Party v. Henderson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the juvenile court's determination that Mother had neglected A.B. and award of custody to Aunt and Uncle, holding that Aunt and Uncle were not entitled to relief on any of their allegations of error.Mother left A.B., her daughter, for nearly one year in the care of Aunt and Uncle. When Mother came to take A.B. back, Aunt and Uncle filed for custody, alleging that Mother had abused and neglected A.B. The juvenile court determined that A.B. had been neglected by Mother and awarded custody to Uncle and Aunt. The court of appeals reversed, concluding that the juvenile court had erred in its neglect determination. The Supreme Court affirmed, holding that the court of appeals (1) applied the appropriate standard of review; (2) did not err in reversing the neglect determination; and (3) did not err in declining to affirm on the alternative ground of abuse. View "In re A.B." on Justia Law

The Supreme Court reversed the judgment of the district court granting Defendant's motion to dismiss this lawsuit brought by Plaintiff under the Utah Sales Representative Commission Payment Act for allegedly failing to pay commissions it owed to her, holding that the Act's writing requirement is not a precondition for recovery.In her complaint, Plaintiff claimed that Defendant violated the Act by failing to pay commissions for sales that she made while working as a commissioned sales agent for the company. Defendant filed a motion to dismiss, arguing that because there was no signed writing there could be no recovery under the Act. The district court granted the motion. The Supreme Court reversed, holding (1) under the plain text of the Act, the writing requirement is not a prerequisite for a sales representative to sue a principal under the Act; and (2) therefore, the district court erred in granting Defendant's motion to dismiss. View "Williamson v. MGS By Design, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that Bonner County, an Idaho political subdivision, had failed to demonstrate to Western Insurance Company's Liquidator that Pend Oreille Bonner Development LLC's failure to complete several municipal projects had cost it anything, holding that the court's finding were not against the clear weight of the evidence.Bonner County contracted with Pend Oreille to construct the projects at issue and required Pend Oreille to obtain multiple surety bonds, which Pend Oreille purchased through Western. Pend Oreille defaulted on the projects. Bonner County filed a claim with the Liquidator of Western, which had been placed in liquidation, to recover the surety bonds. The district court entered judgment against Bonner County. The Supreme Court affirmed across the Board, holding that the district court did not err when it (1) admitted extrinsic evidence to determine the parties' intent; (2) read the statute to provide that a liquidator can amend a determination of claims in response to charged circumstances; and (3) made its findings. View "Bonner County v. Western Insurance Co." on Justia Law