Justia Utah Supreme Court Opinion Summaries

Appellant brought suit against his former employer, EnvironMax, and its directors to recover the value of shares he received to offset wages owed to him by the company - shares he claimed were diluted by corporate misdeeds. The district court dismissed Appellant's suit on summary judgment, concluding that the claim was derivative in nature and that Appellant lacked standing to assert it directly. In so ruling, the court concluded that EnvironMax was not a closely held corporation subject to an exception to the general rule requiring shareholder suits to be filed derivatively and that Appellant's direct claims were otherwise foreclosed by his failure to utilize the Utah dissenters' rights statute. The Supreme Court reversed, holding (1) because Appellant's alleged injury was an individual and not a collective one in common with all shareholders, Appellant was entitled to sue individually and not required to pursue his claim derivatively; and (2) the dissenters' rights statute does not preempt direct actions rooted in breach of fiduciary duty, such as the one brought by Appellant. View "Torian v. Craig" on Justia Law

Defendant was convicted of aggravated sexual abuse of a child, a first-degree felony, and dealing in material harmful to a minor, a second-degree felony. Defendant appealed his convictions to the court of appeals, asserting he should be granted a new trial because his trial counsel was ineffective. Specifically, Defendant contended that trial counsel did not properly investigate or exploit discrepancies in the victim's statements about whether the abuse occurred in 2002 or 2003. The court of appeals agreed and granted a new trial on both charges. The State conceded that Defendant's counsel acted ineffectively in defending the sexual abuse conviction, but petitioned for writ of certiorari on the harmful materials conviction. The Supreme Court affirmed the court of appeals' conclusion that Defendant was entitled to a new trial on the harmful materials conviction, holding that trial counsel's failure to press the time discrepancy was prejudicial. Remanded. View "State v. Moore" on Justia Law

The Judicial Conduct Commission recommended a reprimand against the Honorable Keith L. Stoney due to the issuance of an excessive warrant. Judge Stoney argued before the Supreme Court that the excessive amount of the warrant was a mistake not amounting to misconduct. The court agreed and declined to discipline Judge Stoney, holding (1) the record evidence did not support the Commission's conclusion that Judge Stoney issued a warrant with improper intent; (2) Judge Stoney's mistake did not violate the Code of Judicial Conduct; and (3) because parties to a judicial discipline proceeding are not required to marshal evidence, the Court did not need to dismiss Judge Stoney's brief for failure to marshal the evidence supporting the Commission's order. View "In re J. Stoney" on Justia Law

The State filed a petition that charge D.B. as a principal with theft and criminal trespass for entering a construction site and removing a pair of bolt cutters. The juvenile court adjudicated D.B. a delinquent as an accomplice on both counts. The court of appeals affirmed. D.B. filed a petition for writ of certiorari, claiming that he did not receive adequate Sixth Amendment notice that he may be adjudicated delinquent as an accomplice for the charges. The Supreme Court reversed the delinquency adjudication on the criminal trespass charge but affirmed it on the theft charge, holding (1) D.B. received constitutionally adequate notice through trial testimony that he faced accomplice liability for theft; but (2) the juvenile court adjudicated D.B. delinquent as an accomplice for criminal trespass without notice. Remanded. View "D.B. v. State" on Justia Law

Defendant was convicted of sexual abuse of a child. At trial, the court admitted evidence of two prior uncharged sexual assaults by Defendant. On appeal, Defendant challenged the admissibility of that evidence under Utah R. Evid. 404(b), asserting either that it was not offered for a non-character purpose or that its probative value was substantially outweighed by a risk of unfair prejudice. The court of appeals deemed the evidence admissible for two non-character purposes and affirmed. The Supreme Court (1) reversed the conviction, holding (i) the court of appeals erred in affirming the admissibility of evidence of Defendant's uncharged misconduct offered to prove his specific criminal intent, which was not a legitimately disputed issue at trial; and (ii) the State's evidence was not admissible to prove Defendant acted in conformity with a plan to entice and abuse young men, as the evidence did not demonstrate that Defendant entered a preconceived, overarching design to commit the acts in question; and (2) remanded for a new trial, leaving the door open for the State to offer its evidence on grounds different from those adopted by the trial court or court of appeals. View "State v. Verde" on Justia Law

Plaintiff underwent several medical procedures performed by Defendants, two medical doctors. Two years and three months after the treatment ended, Plaintiff filed a medical malpractice claim against Defendants. Upon a motion by Dr. Grigsby, one of the doctors, the district court dismissed Plaintiff's claim, finding that the claim was barred by the two-year statute of limitations. The court of appeals reversed. The Supreme Court affirmed but on different grounds, holding (1) the court of appeals correctly found that, as a matter of law, Dr. Grigsby failed to show Plaintiff filed her claim more than two years after she discovered or should have discovered her legal injury; but (2) when a plaintiff alleges a course of negligent treatment, a defendant may show that the claim is barred by the two-year statute of limitations without identifying the specific procedure within the course of treatment that caused the patient's injury. Rather, to prevail, a defendant need only show that the plaintiff filed her claim more than two years after she discovered that the course of treatment was negligent. Remanded. View "Arnold v. Grigsby" on Justia Law

Defendant was charged with possession of methamphetamine and drug paraphernalia after a search of his motel room. The district court declined to bind Defendant over for trial at a preliminary hearing, concluding that every reasonable inference from the evidence was that Defendant did not know of the presence of the drug residue and paraphernalia, and therefore, without evidence of an intent to exercise control, there could be no inference of possession of drug residue or paraphernalia. A divided court of appeals affirmed. The Supreme Court reversed, holding (1) the magistrate's and court of appeals majority's concerns with the evidence were insufficient to foreclose a finding of probable cause; (2) the magistrate and court of appeals overstepped their bounds in favoring Defendant's inference that he "didn't know the drugs were there" as stronger than the prosecution's alternative; and (3) the lack of evidence concerning the exclusivity of Defendant's control and access to the motel room did not defeat the prosecution's showing of probable cause. Remanded with instructions to bind Defendant over for trial. View "State v. Ramirez" on Justia Law

In 2005, Allen Grazer obtained a judgment against Gordon Jones and Richard Barney for breach of contract. To satisfy the judgment, property held by Jones and Barney was sold at a sheriff's sale and purchased by Grazer's attorney on his client's behalf. Jones and Barney assigned their redemption interests to the Olsen Trust, which attempted to redeem the property under Utah R. Civ. P. 69C(c). Grazer challenged that attempt as invalid because it was not in full compliance with Rule 69C(c). The district court granted partial summary judgment in favor of the Olsen Trust, concluding the Trust had substantially complied with the rule. The court of appeals affirmed. The Supreme Court affirmed on somewhat different grounds, holding (1) Rule 69C(c) cannot reasonably be read to require superfluous service of documents on the party who was ultimately their source; and (2) the Olsen Trust's redemption was valid and enforceable despite alleged deficiencies under Rule 69C(c) because the Trust fulfilled all non-superfluous requirements of the rule. View "Grazer v. Jones" on Justia Law

After Michael G. Kampros's death, Mark Green and Sophie Gibson became trustees of the Michael G. Kampros Family Trust. Willow Rapela, Kampros's daughter and the successor trustee, requested removal of Green and Gibson pursuant to section 75-7-706(2)(d) of the Utah Trust Code. The district court granted her request with respect to Gibson but declined to remove Green. The district court held that Green had more experience and better qualifications than Rapela to manage the Trust's assets. As a result the district court concluded that Green's removal would not serve the best interests of the Trust's beneficiaries. The Supreme Court affirmed, holding (1) the district court properly concluded that removal of Green did not serve the beneficiaries' best interests; (2) the district court correctly held that Green's personal interests the LLCs in which the Trust also owned interests did not constitute an impermissible conflict of interest because Kampros knew about Green's interests at the time he appointed Green trustee; and (3) the district court permissibly compared Green's and Rapela's experience and qualifications when evaluating whether removal would serve the beneficiaries' best interests. View "Rapela v. Green" on Justia Law

This appeal was rooted in a dispute over an arbitration award. Each party had selected an arbitrator, and a third neutral arbitrator was selected by the two party-appointed arbitrators. Appellee argued that the award should be vacated because one of the party-appointed arbitrators did not disclose that he was first cousins with one of the shareholders in the opposing counsel's law firm. The district court granted Appellee's motion to vacate arbitration award. The Supreme Court reversed, holding (1) under section 129 of the Utah Uniform Arbitration Act (UUAA), there is no appeal of right from a district court order denying confirmation of an arbitration award, vacating the award, and directing a rehearing; (2) party-appointed arbitrators are held to the disclosure standards of the UUAA and not the standards that apply to neutral arbitrators; and (3) the UUAA does not support vacatur in this case, as (i) under subsection 113(4) of the UUAA, the failure to disclose a relationship can support vacatur only if it also meets one of the provisions outlined in subsection 124(1)(b) of the UUAA; and (ii) none of those provisions was shown in this case. View "WestGate Resorts, Ltd. v. Adel" on Justia Law