Justia Utah Supreme Court Opinion Summaries

Appellants Marion Energy (Marion) and the State of Utah School and Institutional Trust Lands Administration (the Trust) leased and owned oil and gas deposits that lay underneath property owned by the KFJ Ranch Partnership (KFJ). To build a road to access their deposits, Marion and the Trust sought to condemn a portion of KFJ's land. To do so, they relied on a statute that permits the exercise of eminent domain for the construction of roads to facilitate the working of "mineral deposits." At issue was whether the phrase "mineral deposits" as used in the statute was intended by the legislature to encompass oil and gas deposits. The district court granted KFJ's motion to dismiss, concluding that the statute did not provide authority to take land for roads to access oil and gas deposits. On appeal, the Supreme Court affirmed, holding (1) the statute is ambiguous as to whether "mineral deposits" includes oil and gas, and (2) because the Court strictly construes an ambiguous statute purporting to grant the power of eminent domain against the condemning party, Marion and the Trust were not authorized by the statute to condemn KFJ's land. View "Marion Energy, Inc. v. KFJ Ranch P'ship" on Justia Law

Carter and Glenada Iverson were killed in a head-on collision with an underinsured motorist while driving a vehicle covered by their policy with State Farm. The personal representative of the Iversons' estate requested that State Farm provide underinsured motorist (UIM) coverage in an amount equal to the liability policy limits of $100,000. State Farm offered $20,000, the limit under the Iversons' policy for the UIM claims. Iverson sued State Farm in district court. The Supreme Court granted certification to answer whether an insurer may provide lower limits for underinsured motorist coverage than for liability coverage under Utah law. The Court concluded that (1) such coverage may comply with Utah law if the insurer follows the consumer notification requirements contained in the Utah Code; (2) because notification requirements differ depending on when the insured's policy was issued, a court must first determine whether a new policy existed on or after January 1, 2001; and (3) a new policy exists on or after this date when the insurer and the insured enter into a new contractual relationship or if changes are made to the terms of an existing insurance contract that materially alter the levels of risk contained in the contract. View "Iverson v. State Farm" on Justia Law

In a 1905 water exchange agreement, Big Ditch Irrigation Company conveyed its Big Cottonwood Creek water right to the Salt Lake City Corporation in exchange for the City's commitment to supply Big Ditch with a specified quantity of irrigation-quality water from City sources. Concerned that Big Ditch was infringing upon the City's water rights, the City initiated this case against Big Ditch and four Big Ditch shareholders in district court. The City sought declaratory judgment on several issues. Big Ditch and the shareholders counterclaimed. The district court granted summary judgment in favor of the City on most major issues. On appeal, the Supreme Court held that the district court properly dismissed the defendants' counterclaims and correctly concluded that the City holds title to the water rights conveyed in the agreement. The Court held, however, that the district court erred in (1) determining that Big Ditch did not have a right to file change applications; (2) determining that the parties had modified the agreement or, alternatively, that Big Ditch was estopped from enforcing its right to the amount of water specified in the agreement; and (3) refusing to dismiss the City's claims against the shareholders. View "Salt Lake City Corp. v. Big Ditch Irrigation Co." on Justia Law

Marilyn Hamblin, the owner of a water right, filed a permanent change application with the state engineer seeking to change her water right's place of use and point of diversion. The state engineer denied the application, declaring that Hamblin had forfeited her water right. Hamblin filed a petition for judicial review. The district court granted the state engineer's motion for summary judgment and denied Hamblin's cross-motion for summary judgment, basing its decision primarily on the determination that Hamblin's water right had been forfeited by operation of law by her nonuse. The Supreme Court reversed and remanded, holding that the state engineer lacked statutory authority to consider non-adjudicated forfeiture when making a decision to approve or reject a permanent change application. View "Jensen v. Jones" on Justia Law

Chance Robinson was charged with unlawful possession or use of a controlled substance based on the presence of methamphetamine in his bloodstream. The charge was grounded on provisions of the Utah Controlled Substances Act that make it unlawful for any person to "knowingly and intentionally" have "any measurable amount of a controlled substance in [his or her] body." Robinson pleaded guilty to the charges. On appeal Robinson argued that Utah's measurable amount provision violates the Utah and United States Constitutions. The Supreme Court affirmed the decision of the district court, holding (1) the provision does not violate the due process or the uniform operation of laws clause of the Utah Constitution; (2) the provision does not violate the constitutional principles set forth in Robinson v. California because it punishes the act of using or being under the influence of a controlled substance while in utah and requires the State to prove that such use was knowing and intentional; and (3) the provision does not violate the Due Process Clause of the Fourteenth Amendment. View "State v. Robinson" on Justia Law

Several Utah counties appealed a tax court's valuation of T-Mobile's taxable Utah property, arguing the valuation did not give proper deference to the Commission's prior assessments, erroneously excluded the value of goodwill, and was based on inadmissible evidence. The Supreme Court affirmed, holding (1) the tax court correctly conducted a trial de novo under the standard of review; (2) the tax court properly excluded T-Mobile's accounting goodwill from its taxable Utah property because the Utah Constitution prohibits taxing goodwill as property; and (3) under the Utah rules of evidence, the tax court did not abuse its discretion when it determined T-Mobile's expert witness was a qualified expert and that his testimony was reliable. View "T-Mobile v. Tax Comm'n and Counties, et al." on Justia Law

Defendant Sandy City and Plaintiffs Mark Haik and several others all hold deeds to the same water right. Sandy City recorded a sales agreement for the right in 1977, but did not record the deed until 2004. The Plaintiffs purchased the same water right in 2003, and recorded that deed immediately. The district court ruled in favor of the Plaintiffs. The court reasoned that the recorded contract was not sufficient notice to Plaintiffs. The agreement was an executory contract that gave no indication whether the deed to the right was actually delivered. The Supreme Court was asked to decide whether the district court erred in giving the right to Plaintiffs. The Supreme Court found that in some circumstances ârecord noticeâ of an equitable interest in water rights could subvert a claim by another good faith purchaser of the same right, but those circumstances were not present in this case. The Court held that since Plaintiffs were the first to file their deed, they held the water right.

Defendant-Appellant Jeffrey Lenkart was charged with rape, forcible sodomy and two counts of sexual abuse. A jury convicted him on all counts, and he was sentenced to concurrent prison terms. Following his sentencing hearing, Defendant moved to arrest judgment and filed a motion for a new trial. The court denied his motion. On appeal, Defendant raised several errors at trial, including the denial of his motion for a new trial. The Supreme Courtâs review of the record found that Defendant received ineffective assistance of counsel when his trial counsel failed to investigate and present important exculpatory evidence. The Court reversed Defendantâs conviction, and remanded the case for a new trial.

The Oak Lane Homeowners Association (the Association) sought review of the appellate courtâs judgment in favor of Defendants Dennis and Renae Griffin. The previous owners of the Griffinsâ property âhad an understandingâ that the lane in question could only be used with permission. The Griffins had used the lane for ingress and egress for fifteen years. Their neighbors sought to form the Association in order to maintain the lane. When the Association asked the Griffins to join, the Griffins refused, and asserted their intent to continue to use the lane. The Association sought quitclaim deeds from all original owners of the platted lots. After receiving them, the Association placed huge boulders in the edges to prevent the Griffins from accessing their property from the lane. The Association argued that the Defendants did not have a private easement over a private lane. The appellate court found that a private easement was created in favor of the Griffiths because their deed in the subdivisionâs recorded plat showed their property abuts the private lane. On appeal, the Association argued that recognizing the Griffinsâ âeasement by platâ is inconsistent with the state law. The Supreme Court disagreed: â[w]e have repeatedly held that when a property abuts a public roadway, a private easement over that roadway arises in favor of the abutting landowner.â Seeing no reason to distinguish a private lane from a public road, the Court upheld the appellate courtâs grant of summary judgment to the Griffins.

Victims-Appellants T.C. and N.C. are the minor victims of sexual abuse perpetrated by their adopted older brother Zachariah Clark. As part of the restitution ordered during sentencing, the trial court required the defendant to pay the costs of the victimsâ therapy. But as defendant was also sentenced to prison, he had no means to pay those costs. Because defendant was adopted through the Utah Division of Child and Family Services (DCFS), Appellants requested that DCFS be ordered to pay their treatment costs pursuant to state law. That request was ultimately denied. On appeal, Appellants raise several grounds for challenging the district courtâs refusal to order DCFS to pay for their treatment. The Supreme Court did not reach the merits of these contentions because it found that the Appellants had no statutory right to appeal the decision.