Justia Utah Supreme Court Opinion Summaries

Shawn Adel, a former employee of Westgate Resorts, a timeshare company, formed Consumer Protection Group (CPG) to right perceived wrongs stemming from Westgate's offer of certificates to consumers that were virtually irredemable. CPG solicited people who had received certificates to assign their claims to CPG. Westgate sued Adel, claiming intentional interference with existing and potential economic relations, conversion, breach of contract, and violation of the Utah Uniform Trade Secrets Act. Adel and CPG counterclaimed on behalf of 500 claimants, alleging breach of contract, fraudulent inducement, and violation of the Utah Consumer Protection Act. The jury awarded actual economic damages of between $5 and $550 for each claimant and awarded each claimant punitive damages of $66,666. The Supreme Court vacated the jury's punitive damages award, holding that the award violated Westgate's procedural due process rights under Philip Morris USA v. Williams because the statements made by CPG's counsel during closing argument created a risk that the jury would improperly consider harm allegedly caused by Westgate to nonparties when it fixed its punitive damages award. Remanded for a new evaluation of the punitive damages award only. View "WestGate Resorts, Ltd. v. Adel" on Justia Law

After an automobile accident caused severe injury to Plaintiffs, Plaintiffs sued the Utah Department of Transportation (UDOT), alleging that it negligently failed to install median barriers at the scene of the accident. In a special verdict, the jury found UDOT was not negligent, and the court entered a judgment of no award. Plaintiff appealed, and UDOT cross-appealed. The Supreme Court held (1) the district court abused its discretion in refusing to instruct that jury that it should draw no adverse inference from the absence of accident history evidence, and thus the case was remanded for a new trial on that ground; (2) the district court did not err in ruling that the accident history evidence was inadmissible; (3) the district court property handled voir dire and correctly rejected Plaintiffs' proposed jury instructions regarding the statutory damages cap and reserve fund; (4) the jury was properly instructed regarding UDOT's duty of care; and (5) the district court erred in refusing to entertain Plaintiffs' motion to exclude witnesses on the ground that they did not so move at the opening of trial. View "Miller v. Utah Dep't of Transp." on Justia Law

Chad Jones sued his insurance company, Farmers Insurance Exchange, for breach of contract, bad faith breach of contract, and intentional infliction of emotional distress after Farmers denied his claim. Farmers defended by arguing that it did not breach its contract because Jones's claim was "fairly debatable." Farmers claimed this defense must be resolved through summary judgment. The district court granted Farmers' motion for summary judgment. The Supreme Court reversed, holding that the fairly-debatable defense should not be resolved through summary judgment if reasonable minds could differ as to whether the defendant's conduct measures up to the standard required for insurance claim investigations. Remanded. View "Jones v. Farmers Ins. Exch." on Justia Law

The procedural background of the extensive litigation underlying this case was discussed in Madsen IV. Following the Supreme Court's decision in that case, Appellant Nancy Madsen filed a new complaint alleging grounds for the same relief that was sought by the earlier complaint. The new complaint was dismissed as barred by res judicata, and this appeal followed. The Supreme Court affirmed, holding that the litigation preceding the filing of Appellant's new action definitively resolved her claims and erected a res judicata bar to any subsequent complaint raising claims that could have and should have been raised in that litigation. View "Madsen v. JPMorgan Chase Bank, N.A." on Justia Law

Defendant was convicted of aggravated assault and criminal mischief. Defendant appealed his convictions and submitted a hybrid Anders/merits brief. Upon review of Defendant's pro se filings and his counsel's Anders brief, the court of appeals identified only one meritorious issue: the claim that the jury instructions misstated the law regarding aggravated the assault. The court of appeals then affirmed Defendant's conviction based on its interpretation of the aggravated assault statute. On certiorari before the Supreme Court, Defendant challenged the court of appeals' interpretation of the aggravated assault statute and advanced other claims foreclosed by the court of appeals' statutory interpretation. Court affirmed on alternate grounds, holding (1) the court of appeals erred in its interpretation of the statute; but (2) although counsel's failure to object to the instructions resulted in deficient performance, there was no prejudice to Defendant sufficient to justify reversal of the verdict. View "State v. Hutchings" on Justia Law

The Supreme Court granted the State's petition for interlocutory review to address whether a court may grant a criminal defendant's request to waive a jury trial over the prosecution's objection. The district court granted Defendant's waiver of a jury trial in favor of a bench trial because of the court's perceived due process concerns. On appeal, the State argued that the district court erred because it disregarded the clear provisions of Utah. R. Crim. P. 17(c) that require the consent of the prosecution before a defendant may waive a jury trial. The Supreme Court reversed, holding (1) under Rule 17(c), Defendant may not waive a jury trial without the State's consent; and (2) Defendant's due process rights were not implicated in this case. Remanded for a jury trial. View "State v. Greenwood" on Justia Law

Comcast of Utah II, Inc. (Comcast) appealed from the district court's grant of partial summary judgment in favor of Commercial Real Estate Investment, LC (CRE). The district court awarded CRE approximately $1.7 million in liquidated damages, plus approximately $2 million in interest, based on Comcast's breach of contract. On appeal, Comcast challenged the enforceability of the liquidated damages clause in its contract with CRE. At issue on appeal was what law governed review of the enforceability of liquidated damages clauses. The Supreme Court affirmed, holding (1) liquidated damages clauses are not subject to heightened judicial scrutiny but instead are treated like any other contractual provision; and (2) the liquidated damages clause in this contract were not unconscionable, and CRE did not breach its duty to mitigate its damages. View "Commercial Real Estate Inv., LC v. Comcast of Utah II, LLC" on Justia Law

This was an appeal from the probate court's order requiring the State to make an interim payment of the Special Fiduciary's fees incurred in administering the United Effort Plan Trust. The State argued that the probate court abused its discretion and acted contrary to Utah law. The State also challenged the probate court's denial of its motions for reconsideration, extension of time, and contribution. The Supreme Court (1) concluded that the probate court did not abuse its discretion or act contrary to Utah law when it found that justice and equity required the State to make an interim payment to the Special Fiduciary; (2) affirmed the court's grant of the Special Fiduciary's motion for fees; and (3) affirmed the court's denial of the State's other motions. View "Shurtleff v. In re United Effort Plan Trust" on Justia Law

Defendant was charged with aggravated murder and aggravated burglary. After being tried and convicted on both charges, he was sentenced to death. On appeal, Defendant raised numerous arguments concerning his convictions, the imposition of the death penalty, and Utah's death penalty scheme. Defendant's arguments included (1) jury issues, (2) evidence and arguments in the guilt phase of the trial, (3) challenges regarding the death penalty exemption hearing, (4) evidence and arguments in the penalty phase, (5) constitutional challenges to Utah's death penalty scheme, and (6) claims of cumulative error. The Supreme Court rejected each of Defendant's arguments and affirmed Defendants' convictions and sentence. View "State v. Maestas" on Justia Law

Plaintiffs purchased a house from Defendant, who built the house. Plaintiffs later discovered mold in some of the windows and walls and sued Defendant. The jury found in favor of Plaintiffs on their negligence claim but found in favor of Defendant on Plaintiffs' negligent misrepresentation claim. The jury also found that Plaintiffs failed to perform all, or substantially all, of the things the contract required them to do and therefore the jury did not reach the question of whether Defendant breached the contract. The Supreme Court held (1) the economic loss rule prevented recovery of economic damages within the scope of the parties' contract but allowed for recovery of damages to other property or for bodily injury; (2) the trial court did not err when it permitted Dr. Eugene Cole to testify as an expert witness; (3) because Defendant prevailed in his claims under the contract, which provided the only basis for awarding attorney fees, he was entitled to recover attorney fees for the breach of contract suit; and (4) the trial court did not err when it denied Plaintiffs' motion for judgment notwithstanding the verdict. Remanded. View "Reighard v. Yates" on Justia Law