Justia Utah Supreme Court Opinion Summaries

On interlocutory appeal, the Supreme Court reversed the judgment of the district court denying partial summary judgment in favor of the Estate of Miguel Huitron in the underlying tort action, holding that the Estate was entitled to a partial summary judgment order.Plaintiff, the only survivor of a crash caused by Huitron, filed a personal injury lawsuit against the Estate approximately three years after the accident, claiming total damages in the millions. The Estate moved for partial summary judgment, which the district court denied. The Supreme Court reversed, holding that several issues could be decided as a matter of law at the summary judgment stage. The Court remanded the case to the district court to continue the proceedings consistent with this opinion. View "Estate of Huitron v. Kaye" on Justia Law

The Supreme Court affirmed the judgment of the district court denying David Taylor's motion to invalidate an arbitration award in this divorce case on the grounds that it was contrary to public policy to arbitrate divorce actions or, alternatively, arguing that the arbitrator had manifestly disregarded the law, holding that there was no error.After litigating their divorce for a year, David asked Jill to arbitrate. After the arbitrator issued his decision, David filed a motion to invalidate the award under Utah Uniform Arbitration Act 78B-11-107, arguing that the arbitration agreement was not valid or binding in the divorce context for policy reasons. The district court denied David's request and confirmed the arbitration award. The Supreme Court affirmed, holding (1) having participated in arbitration without objection, David was barred from relying on section 78B-11-107 to contest the arbitration award; and (2) there was no reason to invalidate the arbitration award for manifest disregard of the law. View "Taylor v. Taylor" on Justia Law

The Supreme Court affirmed the judgment of the district court granting the State's motion for pretrial detention after charging Defendant with four first-degree felonies connected to an alleged sexual assault, holding that the district court did not err when it denied Defendant bail.In its pretrial motion filed pursuant to Utah Code 77-20-1 the State argued that there was substantial evidence to support the charges against Defendant and clear and convincing evidence that Defendant was a substantial danger to the public and likely to flee if released on bail. The district court granted the motion. The Supreme Court affirmed, holding that there was no error in the district court's determinations. View "State v. Randolph" on Justia Law

In this quiet title action, the Supreme Court affirmed the district court's denial of Plaintiffs' motion for summary judgment, holding that the Wrongful Lien Act, the statute of frauds, and caselaw have not declared that restrictive covenants recorded without the signature of the affected landowner are absolutely void. In 1973, Charles Lewton signed and recorded documents purporting to create a homeowners association (HOA) covering 2,000 acres of land. Landowners purchased properties within the HOA's boundaries. In 2015, Landowners discovered that Lewton had owned just eight acres of the 2,000 acres purported to be included in the HOA, and no other landowners signed the recorded documents. Landowners subsequently brought this action to quiet title to their property, arguing that the HOA and its restrictive covenants were void ab initio based on public policy. The district court denied Landowners' motion for summary judgment, applying the two-factor test set forth in Ockey v. Lehmer, 189 P.3d 51 (Utah 2008). The Supreme Court affirmed, holding that restrictive covenants that are recorded without the signature of the affected landowner are voidable and therefore ratifiable. View "WDIS, LLC v. Hi-Country Estates Homeowners Ass'n" on Justia Law

The Supreme Court reversed the decision of the court of appeals construing F.L.'s motion to intervene in David Chadwick's appeal from his sexual abuse of a child conviction as a motion to file an amicus brief under Utah R. App. P. 25 and allowing her thirty days to file the amicus brief, holding that F.L. should be allowed to proceed as a limited purpose party to assert her privacy interests.F.L. was the alleged victim of the sex crimes charged against Chadwick. During proceedings below, the court granted Chadwick's request to conduct an in camera review of F.L.'s therapy and counseling records. The court then sealed the records, and Chadwick was convicted. On appeal, the court of appeals first unsealed F.L.'s records and allowed Chadwick to make use of those records and then granted F.L.'s request to reseal her records and strike all references to the records in Chadwick's supply brief. When Chadwick argued on appeal that the sealing order violated his rights F.L. moved to intervene as a limited-purpose party to assert her privacy interests. The court of appeals construed the motion as a request for leave to file an amicus brief and granted it. The Supreme Court granted extraordinary relief, holding that the court of appeals made a mistake of law in not allowing F.L. to intervene as a limited-purpose party. View "F.L. v. Court of Appeals" on Justia Law

The Supreme Court reversed the determination of the court of appeals that Claimant's long drive in a commercial truck was not an unusual or extraordinary activity in comparison to the ordinary activities people perform in their nonworking, everyday lives and vacated the conclusion that there was substantial evidence to support the ALJ's finding that Claimant's "super obesity" was a preexisting condition, holding that Claimant was entitled to benefits.At the end of a three-day drive from Utah to California, Claimant was diagnosed with a blood clot in his left leg, which caused blood clots in his lungs. Claimant could not return to work and sought workers' compensation. Employer disputed the claim, arguing that his injuries were caused by his "super obesity" and that super obesity should be considered a preexisting condition under the circumstances. The ALJ granted benefits, concluding that Claimant had satisfied the Allen v. Industrial Comm'n, 729. P.2d 15 (Utah 1986), test for legal causation. The Labor Commission Appeals Board reversed, concluding that Claimant's work activities were not unusual or extraordinary under Allen. The Supreme Court reversed, holding (1) Claimant's drive to California was an unusual activity; and (2) therefore, Claimant showed legal causation. View "JBS Carriers v. Hickey" on Justia Law

The Supreme Court reversed in part and affirmed in part the judgment of the district court granting Volkswagen SouthTowne's motion for judgment as a matter of law and a new trial after Plaintiff was awarded $2,700,000 on her negligence and strict liability claims, holding that SouthTowne was not entitled to judgment as a matter of law or a new trial.SouthTowne sold Plaintiff a vehicle that was subject to a safety recall because of defective fuel injection lines. After buying the car, Plaintiff was diagnosed with carbon monoxide poisoning. A mechanic discovered that the safety recall had not been performed on Plaintiff's vehicle. A jury returned a verdict in favor of Plaintiff, but the district court entered post-trial orders concluding that Plaintiff had failed sufficiently to establish the applicable standard of care. The Supreme Court reversed in part, holding (1) the cumulative evidence adduced at trial was legally sufficient to satisfy the element of causation; and (2) the trial court erred in basing its ruling conditionally granting a new trial to SouthTowne because the ruling was based on issues that Plaintiff was not given notice and an opportunity to be heard on. View "Smith v. Volkswagen Southtowne, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating Defendant's convictions on the grounds that his counsel had been ineffective, holding that errors on the part of trial counsel did not prejudice Defendant.Defendant was convicted of murder and several related charges. The court of appeals vacated the convictions, determining that trial counsel was ineffective in failing to object to the use of evidence about Defendant's silence while being arrested and in not objecting to the manslaughter jury instruction, prejudicing Defendant. The Supreme Court reversed, holding (1) defense counsel was ineffective for not objecting to the manslaughter jury instruction, which incorrectly shifted the burden of proof for imperfect self-defense, but the error was not prejudicial; and (2) assuming that defense counsel was ineffective for failing to object to commentary by the prosecution in Defendant's silence after arrest, the error was not prejudicial. View "State v. Bonds" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing the challenges brought by Salt Lake City to four provisions of the Utah Inland Port Authority Act, holding that the challenged zoning provisions did not violate the Utah Constitution.The Act requires that Salt Lake City, West Valley City, and Magna adopt specific zoning regulations and permissions favorable to developing an inland port in the area. Salt Lake brought this action alleging that four provisions of the Act violated the Utah Constitution's Uniform Operation of Laws and Ripper clauses. The district court rejected the City's claims. The Supreme Court affirmed, holding (1) the zoning provisions were rationally related to a legitimate legislative purpose and therefore did not violate the Uniform Operation of Laws Clause; and (2) the zoning provisions did not delegate municipal functions in violation of the Ripper Clause. View "Salt Lake City Corp. v. Inland Port Authority" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that the conduct of two court personnel while sharing a nonpublic courthouse elevator with a jury during trial triggered a rebuttable presumption of prejudice against Defendant, holding that the court of appeals did not err.The court personnel in this case - a uniformed highway patrolman and a court IT technician - told the jurors, in so many words, to find Defendant guilty and to "hang him." The trial court bailiff also stood in the elevator but did not intervene in the exchange. The court of appeals reversed Defendant's conviction and remanded the case for a new trial. The Supreme Court affirmed, holding that the impermissible contact violated Defendant's right to an impartial jury and triggered a rebuttable presumption that Defendant was prejudiced as a result. The Court remanded the case to the district court for a determination of whether the State met its burden to rebut this presumption. View "State v. Soto" on Justia Law