Justia Utah Supreme Court Opinion Summaries

Sanpete America purchased 110 acres of farmland and water rights from Christian Willardsen pursuant to a land purchase agreement and a warranty deed. After discovering problems with respect to the conveyance of the water right at issue, Sanpete America filed a complaint against Willardsen and Douglas Neeley, Willardsen's attorney, asserting various causes of action and seeking damages. Two successive district court judges issued judgments dismissing Sanpete America's claims against Willardsen and Neeley. On appeal, the Supreme Court affirmed both judges' conclusion that Sanpete America was entitled to no damages and judgment dismissing Sanpete America's claims, holding (1) Willardsen conveyed his portion of the water right to Sanpete America under a warranty deed, (2) Willardsen breached no covenants in the deed, and (3) Neeley's actions were not the cause of Sanpete America's alleged damages. View "Sanpete America, L.L.C. v. Willardsen" on Justia Law

Curtis Allgier was charged with aggravated murder, disarming a peace officer, aggravated escape, aggravated robbery, and aggravated attempted murder. While Allgier's case was pending, the district court received a letter written by an inmate in county jail alleging that Allgier had admitted his guilt to the inmate. After the court provisionally sealed the letter, the local media filed a motion to unseal the letter. The district court granted the motion, concluding that the letter was a court record under the Utah Code of Judicial Administration (UCJA) and that the public had a right of access to the letter. The Supreme Court granted Allgier's petition for interlocutory appeal of the district court's ruling. The Court affirmed the district court's decision to unseal the letter, holding (1) the district court correctly determined that the letter at issue was entitled to a presumptive right of public access under the UCJA, and (2) the district court correctly concluded that Allgier failed to overcome that presumptive right of public access. View "State v. Allgier" on Justia Law

Mother and Stepfather filed a petition in the district court to terminate the parental rights of Father. At the same time, Stepfather filed an adoption petition in which he sought to adopt Father's children. The district court terminated Father's parental rights. The court of appeals reversed the district court's order and remanded, concluding that it was unclear whether the district court had jurisdiction to to terminate Father's parental rights. The Supreme Court granted certiorari and reversed the court of appeals' decision, holding (1) the court of appeals did not err when concluding that an adoption petition must be filed before a district court has jurisdiction to consider a petition to terminate parental rights; and (2) the court of appeals erred in concluding that, in the context of a stepparent adoption, a stepparent must satisfy the requirements contained in section 78B-6-135(7)(b) of the Utah Adoption Act before a district court is vested with authority to consider a petition to terminate parental rights. Remanded. View "In re R.B.F.S." on Justia Law

A highway patrol trooper noticed a car driven by Vance Morris did not have a visible license plate. Once he pulled Morris over, the trooper realized the car had a valid temporary registration tag displayed in its rear window. The trooper approached and spoke to Morris, ultimately gathering evidence leading to Morris's conviction for, inter alia, possession of a controlled substance and driving under the influence of alcohol or drugs. The court of appeals reversed, concluding that once the trooper realized his mistake, he lost the reasonable suspicion that justified the traffic stop, and any contact or further detention of Morris was unreasonable. The Supreme Court reversed, holding (1) when an officer acting in good faith is reasonably mistaken about the grounds for a traffic stop, he may initiate contact with the driver to explain his mistake but may not detain the driver any further, and, if during this encounter, new reasonable suspicion of criminal activity arises, the officer may act accordingly; and (2) because the trooper's stop was based on an objectively reasonable mistake of fact, he was allowed to approach Morris, and the odor of alcohol detected during this encounter allowed the trooper to constitutionally detain Morris further. View "State v. Morris" on Justia Law

This case concerned the application of payments made in connection with a real estate transaction between Kang Park and Marsha Park and Gary Stanford. The district court granted summary judgment to the Parks, determining, as a matter of law, that none of the payments Stanford submitted to the Parks could be credited toward a personal guaranty Stanford had made on the note payable to the Parks. The court of appeals affirmed the district court's grant of summary judgment, concluding that no evidence indicated the Parks had actual knowledge that Stanford intended for the past payments to apply to his guaranty and no agreement or contractual provision expressly required the Parks to make such an application. On certiorari, the Supreme Court reversed, holding (1) the court of appeals applied the wrong test in its holding, and rather, a rule in which payments are credited toward a personal guaranty when the recipient of the payments has a reasonable basis to know the payments were submitted in satisfaction of the guaranty governed the application of payments toward a personal guaranty; and (2) genuine issues of material fact precluded summary judgment under the rule and the record required further development. Remanded. View "Park v. Stanford" on Justia Law

After a Robin Doyle and Doug Doyle obtained a litigated custody decree, Robin petitioned the trial court for a modification of the custody of her son, maintaining that there had been a substantial and material change in circumstances when Robin moved from Colorado back to the same neighborhood as her son. The court granted her petition, transferring custody from the child's father, Doug, to Robin. On appeal, the court of appeals affirmed in part and reversed and remanded for recalculation of child support. The Supreme Court affirmed the judgment of the trial court, holding (1) formal bifurcation of the changed circumstances and best interests proceedings was not required by Utah law and the trial court appropriately received evidence regarding changed circumstances and best interest; (2) the trial court correctly found a change in circumstances even when there was no change in the custodial parent's circumstances; and (3) the trial court had ample authority to modify the child support order in the absence of a specific request in Robin's petition for modification of custody. View "Doyle v. Doyle" on Justia Law

Barbara and Steven Selvig, as sellers, and Blockbuster Enterprises, as buyer, entered into a real estate purchase contract for the purchase of a bed and breakfast. The contract specified that the deed to the property would be recorded when Blockbuster paid the full purchase price. Before paying the full purchase price, however, Blockbuster recorded the deed. The sellers sued in district court on several theories of liability. The district court granted Blockbuster's motion to dismiss, dismissing (1) the seller's claims for breach of contract and breach of the covenant of good faith and fair dealing, holding that the sellers had elected their remedy pursuant to an election of remedies provision in the contract by keeping the earnest money deposit; and (2) the seller's unjust enrichment claim. The Supreme Court affirmed in part and reversed in part, holding (1) the district court erred in dismissing the seller's contractual claims because the election of remedies provision does not apply to a breach of contract claim out of a wrongful recording of the deed; and (2) the district court correctly dismissed the seller's claim for unjust enrichment because the sale of the property was covered by a written contract. View "Selvig v. Blockbuster Enterprises, L.C." on Justia Law

Baby E.Z., the child of John Wyatt and the birth mother, who were never married, was born in Virginia. After the birth, the birth mother consented to an adoption, after which Wyatt initiated custody and visitation proceedings in a Virginia court. The prospective parents then filed a petition for adoption in Utah district court. Wyatt filed a motion in the Utah court contesting the adoption and requesting permission to intervene. The Utah court denied Wyatt's motion, holding that he had waived his rights to the child, that he could not intervene, and that his consent to the adoption was not required. Subsequently, the Virginia court issued an order granting Wyatt custody of the baby. On appeal, Wyatt argued that the federal Parental Kidnapping Prevention Act (PKPA) deprived the Utah district court of jurisdiction over the adoption proceeding and required enforcement of the Virginia court order awarding him custody of the baby. The Supreme Court affirmed the district court's denial of Wyatt's motion, holding (1) the PKPA applied to the adoption proceedings, but that Wyatt waived any claim under the PKPA by failing to raise the statute below; and (2) Wyatt failed to timely assert his parental rights under Utah law. View "In Re Baby E.Z." on Justia Law

Defendant Douglas Lovell was convicted of aggravated murder. Following the entry of his guilty plea, Lovell moved to withdraw it. The district court initially held the motion was untimely, but the Supreme Court reversed that holding and remanded the case. In the district court, Lovell argued he had good cause to withdraw his plea because (1) the trial court failed to strictly comply with Utah R. Crim. P. 11(e), which sets out the requirements for a lawful guilty plea, and (2) there was good cause for him to withdraw his plea because his trial counsel was ineffective. The district court (1) held that the trial court complied with rule 11(e) and even if it did not, the error did not amount to good cause to allow Lovell to withdraw his plea because Lovell did not show that but for the error he would not have pled guilty; and (2) rejected Lovell's claims of ineffective assistance of counsel. On appeal, the Supreme Court reversed the judgment of the district court, holding that the trial court's failure to strictly comply with rule 11(e) constituted good cause to allow Lovell to withdraw his guilty plea. View "State v. Lovell" on Justia Law

The Utah Department of Transportation (UDOT) contracted with Meadow Valley Contractors (MVC) for a highway construction project. MVC subcontracted the paving work to Southwest Asphalt Paving. After UDOT refused to allow Southwest to use ribbon paving and assessed MVC a thickness-laying penalty, MVC filed a compliant against UDOT, alleging that (1) it incurred costs not contemplated by the contract as a result of UDOT's prohibition on ribbon paving, and (2) the thickness penalty assessed by UDOT was unwarranted. UDOT denied MVC claims. Southwest then filed a complaint in district court in MVC's name against UDOT alleging breach of contract. The trial court (1) concluded that UDOT breached its contract with MVC by refusing to allow ribbon paving on the construction project, and (2) denied MVC's claim that UDOT had erroneously imposed a paving-thickness penalty. On appeal, the Supreme Court reversed in part and affirmed in part, holding (1) UDOT did did not breach its contract with MVC when it forbade MVC and Southwest from using ribbon paving, and (2) there was sufficient evidence to support the trial court's conclusion that UDOT's interpretation of the contract regarding paving thickness was more reasonable than MVC's interpretation. View "Meadow Valley v. UDOT" on Justia Law