Justia Utah Supreme Court Opinion Summaries

This case involved a medical malpractice lawsuit brought by the Wilsons on behalf of their son, Jared. The Wilsons alleged that employees of IHC Hospitals breached their duty of care during Ms. Wilson's labor and delivery of Jared. The Wilsons further claimed that IHC's negligence caused Jared to suffer severe brain damage. The jury found that IHC did not act negligently. The Supreme Court vacated the jury's verdict, holding (1) IHC's trial tactics violated the court's in limine order excluding collateral source evidence at trial, misled the trial court, and substantially prejudiced the jury; (2) the collateral source rule precludes both explicit reference and methodical allusion to collateral source benefits; and (3) because IHC repeatedly disregarded the in limine order and violated the collateral source rule, the case must be remanded. View "Wilson v. IHC Hosps., Inc." on Justia Law

Stephen Maxfield challenged the results of the 2010 gubernatorial election under Utah's election-contest statute, asking the district court to declare him and his running mate the lieutenant governor and governor of Utah, respectively. The court dismissed the petition, concluding that the statutory grounds for an election contest did not encompass Maxfield's claims. The Supreme Court affirmed, holding (1) the district court did not err in disposing of the case by deciding Herbert's timely-filed Rule 12(b)(6) motion; (2) the nature of the hearing held in district court was appropriate, and Maxwell's right to a timely hearing was waived; and (3) the district court did not err in refusing to allow Maxfield to bring an election contest based on allegations of campaign finance violations. View "Maxfield v. Herbert" on Justia Law

A jury convicted Defendant of aggravated robbery. The jury found that Defendant was subject to a one-year enhancement of his sentence because a dangerous weapon was used in the course of the robbery. The court of appeals affirmed. Defendant appealed, contending that the State failed to prove he had knowledge of the principal's possession of a dangerous weapon. The Supreme Court affirmed the conviction of aggravated robbery with a one-year penalty enhancement after clarifying the mental state required for the dangerous weapon aggravator in Utah Code 76-6-302(1)(a), holding (1) because the legislature has made no indication that it is a strict liability offense, the statutory aggravator requires the culpable mental state of recklessness; but (2) Defendant's claims on appeal did not require reversal because he did not demonstrate that the errors caused him prejudice. View "State v. Jimenez" on Justia Law

Plaintiffs brought suit against a law firm and its attorneys for their role in executing civil discovery orders. The orders authorized entry into Plaintiffs' home to seize electronic files from Plaintiffs' computer and other electronic devices. Plaintiffs raised several causes of action based largely on the theory that the execution of the civil discovery orders constituted an illegal warrantless search. The district court granted Defendants' motion for judgment on the pleadings, and the court of appeals affirmed. The Supreme Court affirmed on alternate grounds, holding (1) the judicial proceedings privilege extends to attorneys' conduct in representing their clients; and (2) as applied in this case, the privilege barred all of Plaintiffs' claims. View "Moss v. Parr Waddoups Brown Gee & Loveless" on Justia Law

Roger Hooban sued Unicity International for breach of a distribution agreement. The district court entered summary judgment for Unicity, holding that Hooban was not a party to the agreement and lacked standing to sue for its enforcement. Unicity then filed a motion for attorney fees under Utah's reciprocal attorney fees statute, Utah Code 78B-5-826. The district court denied the motion on the ground that section 826 was inapplicable given that Hooban was not a party to the underlying contract. The court of appeals reversed, interpreting the Supreme Court's decision in Bilanzich v. Lonetti to dictate a fee award in litigation that is based on a written contract where the contract allows at least one party to the litigation to recover fees. The Supreme Court affirmed, holding (1) section 826 applied in this case; and (2) the statute thus authorized the court to award fees to Unicity. View "Hooban v. Unicity" on Justia Law

Petitioner Jones & Trevor Marketing appealed the dismissal of its suit against the owners of Financial Development Services, Jonathan Lowry and Nathan Kinsella, alleging various contract and tort claims based on an alter ego theory of liability. The district court held that Petitioner had not demonstrated sufficient facts to support its alter ego theory and therefore granted summary judgment against Petitioner on its tort and contract claims that rested on its alter ego theory. The court of appeals affirmed. The Supreme Court affirmed, holding that Petitioner failed to provide affirmative evidence establishing a genuine material dispute on its alter ego theory. View "Jones & Trevor Mktg. v. Lowry" on Justia Law

This dispute centered around two roads owned by the Maceys, their company Family Link, and the remaining defendants (Defendants). Petitioner Nadine Gillmor previously brought suit against the Maceys seeking to interpret and enforce the terms of a settlement agreement purporting to give the Gillmors a limited private easement over one road and limited access over the other road. The court of appeals held that Gillmor had a limited private easement over the roads but that the easement would not pass on to her children from a prior marriage. Gillmor later brought two claims for access over the roads, asserting that the roads were subject to condemnation for a public access easement and that the roads had been continuously used as public thoroughfares for a period of ten years and were thus dedicated to public use as a "highway by use" under Utah Code 72-5-104. The district court dismissed the complaint based on res judicata and imposed sanctions on Gillmor's attorney for filing a claim without a basis in law. The Supreme Court (1) held that Gillmor's claims were not barred by res judiciata; and (2) vacated the imposition of sanctions. Remanded for adjudication of Gillmor's suit on the merits. View "Gillmor v. Family Link, LLC" on Justia Law

Dentist purchased dental practice management software from Company to aid his patient data requirement. The contract between Dentist and Company limited Dentist's remedies for damages in tort caused by defects in the Company's software. Although Company warned Dentist to back up his patient data, Dentist's patient data was lost when installing the software. Dentist sued Company under several theories, and the district court granted Company's motion for summary judgment. Dentist appealed only the order granting summary judgment on his tort claims. The Supreme Court affirmed, concluding that the limitation of liabilities clause in the contract was enforceable, as provisions in software contracts allocating the risk of such a loss to the consumer are enforceable. View "Blaisdell v. Dentrix Cental Sys., Inc." on Justia Law

The State appealed the dismissal of its complaint against seventeen pharmaceutical companies, which the State alleged defrauded Utah's Medicaid program by reporting inflated drug prices. In its complaint, the State pursued two causes of action, violation of the Utah False Claims Act (UFCA) and fraudulent misrepresentation. The district court dismissed the claims based on three alternative grounds. The Supreme Court reversed in part and affirmed in part, holding (1) although the State's complaint was insufficiently particular under the appropriate Utah R. Civ. P. 9(b) standard for claims alleging a widespread scheme to commit fraud and submit false claims, it was in the interest of justice to grant the State leave to amend its complaint under the new standard; (2) the district court erred in dismissing the State's claims under Utah R. Civ. P. 12(b)(6) because the State alleged all the elements of its causes of action; and (3) the district court properly applied the one-year statute of limitations to the State's UFCA cause of action and its dismissal of those claims alleged to have arises before April 30, 2006. Remanded. View "State v. Apotex Corp." on Justia Law

Robert Manzanares, a Colorado resident, challenged the district court's order terminating his parental rights in his biological daughter, "Baby B." The district court held that Manzanares's conset to the adoption of Baby B. was not required under Utah law, basing this conclusion on a finding that Manzanares either knew or through "reasonable diligence" could have known of at least one of several "qualifying circumstances" defined by Utah law. Specifically, the court found that Manzanares had knowledge of his girlfriend's plan to flee to Utah to give birth and place their baby for adoption. The Supreme Court reversed after clarifying the standards that govern under the Adoption Act and prior Supreme Court cases, holding (1) the district court's conclusions ran counter to a proper understanding of the statute and were unsupported by the evidence, as there is a difference between a belief and actual knowledge in establishing that a father had notice that a birth and adoption would take place in Utah; and (2) Manzanares could not have known, and did not know, that the birth and adoption would take place in Utah. Remanded. View "In re Baby B." on Justia Law