Justia Utah Supreme Court Opinion Summaries

Dillon Whitney's mother filed a wrongful death suit against the State after Dillon died while in state custody. The State filed a motion to dismiss, arguing that it was exempt from suit under the incarceration exception to the Governmental Immunity Act of Utah. The federal district court denied the motion, and the State appealed. The Supreme Court accepted certification to answer a question of state law and held (1) a juvenile who is placed in an unsecured community-based proctor home is not incarcerated in a place of legal confinement; and (2) accordingly, the incarceration exception to the State's waiver of its sovereign immunity did not apply in this case, and the State remained potentially liable for damages related to Dillon's death. View "Whitney v. Div. of Juvenile Justice Servs." on Justia Law

Ira B. Warne executed a partial revocation of and amendment to the Ira B. Warne family protection trust, the purpose of which was to terminate the interest of one of Ira's sons, Thomas Warne, who had been designated as a beneficiary in the original trust instrument. On summary judgment, the district court (1) invalidated the partial revocation based on the Supreme Court's holding in Bans v. Means; and (2) held that Thomas was entitled to one-half of the personal property of Ira's estate pursuant to the distribution provisions of Ira's will. The Supreme Court reversed, holding (1) the partial revocation complied with Utah Code 75-7-605, which statutorily overruled the holding in Banks; and (2) the distribution of Ira's personal property was governed by the terms of the trust, rather than by Ira's will, and therefore the district court erred in awarding Thomas one-half of that property. Remanded for consideration of whether Ira's partial revocation was a product of undue influence. View "Warne v. Warne" on Justia Law

Miriam Salazar purchased an insurance policy from United Automobile Insurance Company and El Sol Insurance Agency (collectively, United), rejecting underinsured motorist (UIM) coverage by signing United's waiver. After Salazar was involved in an accident, Lopez sued United, arguing that United must provide her with UIM coverage because the waiver did not provide the required reasonable explanation of UIM coverage. The district court granted summary judgment in favor of United. The court of appeals reversed, holding that the waiver did not contain a reasonable explanation, and Lopez was therefore entitled to UIM coverage of $25,000 under the UIM statute. The court then remanded the case with instructions for the district court to enter judgment in favor of Lopez in the amount of $25,000. The Supreme Court held that the court of appeals (1) did not err in finding that United failed to provide a reasonable explanation of the purpose of UIM coverage and when it would be applicable; but (2) erred in instructing the district court to enter judgment for Lopez in the amount of $25,000. Remanded with instructions to determine the amount of damages Lopez actually sustained. View "Lopez v. United Auto. Ins. Co." on Justia Law

Patient received medical treatment from Nurse at Medical Clinic. Nurse prescribed Patient at least six medications. With all of these drugs in his system, Patient shot and killed his wife. Patient subsequently pled guilty to aggravated murder. Patient's children (Plaintiffs) filed suit through their conservator against Nurse, her consulting physician, and Medical Clinic (collectively Defendants), alleging negligence in the prescription of the medications that caused Patient's violent outburst and his wife's death. The district court granted Defendants' motion to dismiss, concluding that Nurse owed no duty of care to Plaintiffs because no patient-health care provider relationship existed at the time of the underlying events between Plaintiffs and Defendants. The Supreme Court reversed, holding that healthcare providers owe nonpatients a duty to exercise reasonable care in the affirmative act of prescribing medications that pose a risk of injury to third parties. View "Jeffs v. West" on Justia Law

At issue in this case was a support order that required Petitioner Steven Hansen to pay child support to his ex-wife. Petitioner subsequently sought to redirect his support payments to a homeless shelter where the child resided for a period of time. The district court declined to order redirection of child support to the shelter, concluding that the support statute did not allow for payments to be redirected. The court of appeals affirmed. The Supreme Court affirmed, holding that because the homeless shelter was not a party to the proceedings and was legally ineligible to become the child's physical custodian in any event, the district court properly denied Petitioner's motion to redirect child support. View "Hansen v. Hansen" on Justia Law

While driving, Jed Price struck another vehicle, killing a passenger in that vehicle. After he consented to accompany an officer to a police station, a magistrate issued a warrant to seize Price's blood for testing to determine his blood-alcohol levels. The blood was tested for the presence of, among other things, THC, and the test results came back positive for the presence of THC. Price was subsequently charged with causing death while driving with a measurable controlled substance and failing to yield the right of way. The district court denied Price's motion to suppress the evidence. Price appealed, arguing that testing for THC was outside the scope of the warrant because the magistrate's probable cause determination was based only on the suspicion that Price had been driving under the influence of alcohol. The Supreme Court affirmed, holding (1) after his blood was lawfully obtained, Price did not have a reasonable expectation of privacy in any contraband in his blood; (2) the test for THC did not infringe on any legitimate privacy interests; and (3) the testing was therefore constitutional. View "State v. Price" on Justia Law

Appellant Robert Manzanares and Carie Terry conceived a child in Colorado. Appellant filed a paternity action in Colorado, seeking to enjoin any adoption proceeding. In Utah, a couple signed a petition for the adoption of Terry's baby. After the baby was born, the couple filed their adoption petition. Meanwhile, a Colorado court granted Appellant's petition for paternity. Appellant then filed in Utah a motion to dismiss the couple's adoption petition. The district court eventually terminated Appellant's parental rights in his biological daughter, Baby B., holding that Appellant's consent to the adoption was not required under Utah law. The court based this conclusion on a finding that Appellant either knew or through reasonable diligence could have known of at least one of several qualifying circumstances defined by Utah law. The Supreme Court reversed, holding that the district court's conclusions ran counter to a proper understanding of the relevant statute and were unsupported by the evidence. Remanded for further findings regarding (1) whether Appellant fully complied with Colorado's requirements to establish his parental rights in Baby B. and to preserve the right to notice of a Colorado adoption proceeding, and (2) whether Appellant demonstrated a full commitment to his parental responsibilities. View "In re Adoption of Baby B." on Justia Law

Von Lester Taylor pled guilty to two capital homicide charges and was sentenced to death. A Utah R. App. P. 23B hearing was later held before the district court, after which the court rejected all of Taylor's claims of ineffective assistance of trial counsel. The Supreme Court affirmed. Taylor's counsel thereafter filed a petition for post-conviction relief, which the district court denied. The Supreme Court affirmed. Taylor then filed a successive petition for post-conviction relief. The district court granted the State's motion to dismiss the petition, holding that all of Taylor's claims were procedurally barred under the Post-Conviction Remedies Act (PCRA) because they were raised, or could have been, but were not, raised in a prior proceeding. The Supreme Court affirmed, holding that Taylor failed to establish that his claims could not have been raised in a prior proceeding and failed to meet any statutory or common law exceptions to the procedural bar. View "Taylor v. State" on Justia Law

Plaintiffs William and Donna Judson secured a default judgment against Wheeler RV Las Vegas on a complaint asserting breach of contract and misrepresentation claims arising out of the Judsons' purchase of a recreational vehicle from Wheeler. Wheeler sought to set aside the default judgment, asserting surprise or excusable neglect in its failure to answer the complaint, suggesting that Wheeler was the wrong party because its predecessor was the entity that sold the Judsons their RV, and questioning their district court's jurisdiction over Wheeler. The district court denied Wheeler's motion. The court of appeals affirmed, concluding that Wheeler failed to make a "clear and specific proffer" of a meritorious defense required as a predicate for setting aside a default judgment under Utah R. Civ. P. 60(b). The Supreme Court reversed, holding that, under the simple pleading standard set forth under Rule 60(b), Wheeler's meritorious defense allegations were sufficient. Remanded to resolve the issue of whether Wheeler established the "surprise and excusable neglect" predicate for setting aside the default judgment. View "Judson v. Wheeler RV Las Vegas, LLC" on Justia Law

At issue in this appeal was the Privilege Tax Statute, which provides that an entity may be taxed on the privilege of beneficially using or possessing property in connection with a for-profit business when the owner of that property is exempt from taxation. But the tax may not be imposed unless the entity using or possessing the exempt property has "exclusive possession" of that property. Alliant Techsystems (ATK) challenged the imposition of a privilege tax on its use of government property. The district court granted summary judgment against ATK, concluding that ATK had "exclusive possession" of federal government property because there was no evidence that anyone other than the government, the landowner, had any possession, use, management or control of the property. The Supreme Court reversed, holding (1) under the Statute, "exclusive possession" means exclusive as to all parties, including the property owner, and thus, exclusive possession exists when an entity has the present right to occupy and control property akin to that of an owner or lessee; and (2) because the record indicated disputed material facts regarding ATK's authority to control the government property, summary judgment was inappropriate in this case. View "Alliant Techsystems, Inc. v. Salt Lake Bd. of Equalization" on Justia Law