Justia Utah Supreme Court Opinion Summaries

This protracted litigation arose out of a real-property exaction imposed on B.A.M. Development, LLC, as a condition of a construction permit for a fifteen-acre residential housing development. Twice the Supreme Court remanded the case for a new trial. After conducting a third trial, the district court concluded that the County's exaction did not violate the Dolan v. City of Tigard rough proportionality standard. The Supreme Court affirmed the district court in all respects, holding (1) the district court did not err by including in its rough-proportionality analysis costs borne by state government entities; (2) the district court did nor err by limiting the scope of its review to B.A.M.'s thirteen-foot road dedication; and (3) B.A.M.'s remaining arguments were meritless or inadequately briefed. View "B.A.M. v. Salt Lake County" on Justia Law

Plaintiff's son, Hayden, was involved in a near-drowning accident in which he suffered severe permanent injuries. Plaintiff subsequently sought coverage for the cost of his treatment from Wasatch Crest Mutual Insurance, under which Hayden was insured. Wasatch Crest was later declared insolvent, and Plaintiff filed a claim against the Wasatch Crest estate. The liquidator of the estate denied Plaintiff's claim, concluding that Wasatch Crest had properly terminated coverage under the language of the plan. The Supreme Court reversed, interpreting the plan in favor of coverage. Plaintiff resubmitted her claim for medical expenses to the liquidator for payment under the Utah Insurers Rehabilitation and Liquidation Act. One year later, Plaintiff filed a motion for summary judgment with the district court. The liquidator subsequently issued a second amended notice of determination denying Plaintiff's claim on the merits. The district court then denied Plaintiff's motion for summary judgment, as Plaintiff had not yet challenged the second amended notice of determination and could do so under the Liquidation Act. Plaintiff appealed the district court's order. The Supreme Court dismissed the appeal because Plaintiff did not appeal from a final judgment and had not satisfied any of the exceptions to the final judgment rule. View "Mellor v. Wasatch Crest Mut. Ins." on Justia Law

Upon adjudication of parental neglect, the Division of Child and Family Services (DCFS) took custody of L.O., a child and an enrolled member of the Navajo Nation, and placed L.O. with a foster family. After L.O.'s natural parents relinquished parental rights, L.O.'s foster family filed a petition for adoption. The Nation filed an objection to the adoption because DCFS failed to abide by the placement preferences contained in the Indian Child Welfare Act and moved the juvenile court to transfer jurisdiction to the Nation. The juvenile court denied the transfer motion. The Nation appealed, and the court of appeals dismissed the case. After the Supreme Court granted certiorari to consider two procedural questions raised by the Nation, the juvenile court granted the foster family's petition to adopt L.O. Filed with the adoption order was a document titled "Navajo Nation's Consent to Adoption." The Supreme Court declined to address the issues raised on certiorari and dismissed the petition for certiorari, holding that the Nation's consent to L.O.'s adoption placement rendered the procedural questions moot. View "Navajo Nation v. State " on Justia Law

After sustaining injuries in an auto accident, Tavis McArthur filed this suit in federal district court to recover underinsured motorist (UIM) benefits under his State Farm automobile insurance policy. The district court granted summary judgment in favor of State Farm, concluding that McArthur had failed to exhaust the liability limits of the tortfeasor's insurance, a precondition of his UIM benefits policy. On appeal, the Tenth Circuit Court of Appeals certified two questions to the Utah Supreme Court. The Supreme Court held (1) exhaustion clauses that require the liability insurer to pay out its full policy limits before permitting payment of UIM benefits are generally enforceable in the State of Utah; and (2) because UIM exhaustion provisions are conditions precedent and not covenants capable of being breached, no showing of prejudice is required to sustain their invocation. View "McArthur v. State Farm Mut. Auto. Ins. Co." 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 Ann. 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 opinion 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 section 826 authorized the court to award fees to Unicity because, had Hooban's theory of the case prevailed in the district court, he would have been a party to the contract and the contract would have allowed Hooban to recover fees. View "Hooban v. Unicity Int'l, Inc." on Justia Law

When Client allegedly failed to pay Firm as agreed under their contract, Firm sued Client for breach. Client counterclaimed for breach of contract and negligence. Client also filed a third-party complaint against Firm's Owner, alleging that Owner was Firm's alter ego and seeking to hold Owner liable for any judgment entered against Firm. The trial court entered (1) a directed verdict on the third-party complaint, and (2) judgment in favor of Client on Firm's breach of contract claim and on Client's counterclaim against Firm. Owner later sought attorney fees under the reciprocal attorney fees statute, Utah Code Ann. 78B-5-826, arguing that, as the prevailing party in the third-party action, he was entitled to a fee. The trial court denied Owner's request, concluding that Owner was not a party to the contract as required to trigger the statute. The court also denied Owner's request for costs. The court of appeals affirmed. The Supreme Court (1) affirmed the court of appeals' decision as to attorney fees under its analysis in Hooban v. Unicity International Inc.; but (2) reversed the court of appeals' decision as to costs based on its reading of Utah R. Civ. P. 54(d). Remanded. View "Bushnell v. Barker" on Justia Law

One of Summit Water Distribution Company's (SWDC) minority shareholders, Bear Hollow Restoration, filed a complaint requesting a review and investigation of SWDC's exemption from public regulation under the now-repealed Utah Admin. R. 746-331-1. The Public Service Commission dismissed the complaint on the basis that SWDC was not a public utility, and therefore, the Commission did not have jurisdiction. The Supreme Court affirmed the Commission's dismissal, holding (1) the allegations in Bear Hollow's complaint were insufficient to establish that SWDC served the public generally or that the Commission had jurisdiction; (2) Bear Hollow was not prejudiced by repeal of Rule 746-331-1 because the rule applied only to internal agency decisions and the underlying substantive law remained in place; and (3) the Commission did not abuse its discretion when it refused Bear Hollow's amended complaint after the original complaint had been dismissed. View "Bear Hollow Restoration, LLC v. Utah Pub. Serv. Comm'n" on Justia Law

The Point of the Mountain Aqueduct is a sixty-inch diameter pipeline that runs along the Draper Canal and transports culinary water to Salt Lake City and other cities in the Salt Lake Valley. Plaintiffs in this case were homeowners who asserted claims challenging Metropolitan Water District's construction of the aqueduct as exceeding the scope of its real property rights along the canal route. The district court granted summary judgment for the Water District. The Supreme Court affirmed the district court's decision in most respects, but reversed the district court's conclusion that (1) Reaches 16-17 were not limited by restrictive covenants; and (2) enclosing the Draper Canal within a buried pipeline was reasonable as a matter of law and so did not exceed the scope of the Water District's property rights in Reach 19. The Court then (1) held that warranty deeds imposed restrictive covenants that run with the land, limiting Reaches 16-17 to canal purposes only; and (2) remanded for a factual determination of whether the canal enclosure was reasonable and did not materially alter the burden to Appellants' land with respect to Reaches 16, 17, and 19. View "Stern v. Metro. Water Dist." on Justia Law

Lemuel Prion pled guilty and mentally ill to three felony charges pursuant to Utah Code Ann. 77-16-104(3). Under the provisions of the statute, Prion was first sentenced to three terms of varying length, all to be served concurrently. As part of his first sentence, Prion was committed to the hospital for evaluation. After his stay there, Prion was released. Based upon the recommendations of the hospital staff and administration, the district court resentenced Prion to serve his three terms consecutively, nearly doubling his prison time. Prion filed a motion to correct his sentence, claiming that his second sentence was statutorily barred and violated the Double Jeopardy Clause of the federal constitution. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed and remanded, concluding that, although the sentencing statute at issue expressly allows for a recall and resentencing at any time during an eighteen-month review period, Prion's resentencing exceeded the bounds of the double jeopardy clause in light of the nature and timeframe of this proceeding. View "State v. Prion" on Justia Law

Steve Richards sued his former domestic partner, Diana Brown, seeking to have the relationship declared to be an unsolemnized marriage. The trial court granted partial summary judgment in favor of Brown, holding that Richards' petition was untimely. The remaining equitable claims went to trial, and ultimately, the trial court found that Brown had been unjustly enriched by Richards' contributions to home improvement and awarded Richards a money judgment. After Brown paid the judgment, Richards appealed the court's dismissal of his unsolemnized marriage claim. The court of appeals (1) held that Richards did not waive his right to appeal, and (2) reversed the trial court's grant of partial summary judgment against Richards on his unsolemnized marriage claim. The Supreme Court affirmed, holding (1) Richards did not waive his right to appeal even though he accepted payment on the unjust enrichment judgment, as a claim of unjust enrichment is separate and district from a claim of unsolemnized marriage; and (2) the court of appeals correctly interpreted the Utah Code Ann. 30-1-4.5 in determining that an end to cohabitation does not necessarily terminate a relationship. View "Richards v. Brown" on Justia Law