Justia Civil Procedure Opinion Summaries

Articles Posted in Utah Supreme Court
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In 2020, the Town of Hideout, Utah, took advantage of a brief window in state law that allowed municipalities to annex unincorporated areas without a petition or county consent. Hideout annexed an area in Summit County, and after receiving a certificate of annexation from the Lieutenant Governor, Summit County challenged the annexation and the related municipal ordinance in district court. The district court ruled in favor of Summit County, finding that it had standing to challenge the annexation and declaring the annexation ordinance invalid.The Supreme Court of the State of Utah reversed the district court's decisions. The court found that the relevant statutory scheme, the annexation code, did not provide Summit County with a legally protectible interest that would allow it to obtain the relief it sought. The court also found that the statutory provisions outside the annexation code that Summit County relied on did not provide it with a legally protectible interest in the controversy. The court further held that the doctrine of public interest standing, on which the district court alternatively relied, was inapplicable in this case.Because the court concluded that Summit County lacked standing to pursue its claims, it also reversed the district court’s award of summary judgment in Summit County’s favor without addressing the merits of Summit County’s claims. The case was remanded to the district court for dismissal. View "Hideout v. Summit County" on Justia Law

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In 2018, a group of citizens in Tooele County, Utah, initiated the process to incorporate an area known as the City of Erda. The incorporation process involved several steps, including obtaining signatures from property owners within the proposed area, conducting a feasibility study, and holding a public vote. After the incorporation was certified by the Lieutenant Governor, three landowners within Erda's boundaries—John Bleazard, Mark Bleazard, and Six Mile Ranch Company—challenged the incorporation. They alleged that the incorporation process violated statutory requirements, including that their signatures were misrepresented in the feasibility study request and that the notice of impending boundary action was untimely.The district court in Tooele County denied motions to dismiss the case brought by the City of Erda and the Lieutenant Governor. They had argued that the landowners lacked statutory standing to challenge the incorporation. The court disagreed, finding that the landowners had a legally protectible interest under the Utah Code, which it interpreted as contemplating the possibility of a challenge to an incorporation.The Supreme Court of the State of Utah reversed the district court's decision. The Supreme Court held that the landowners' claim for declaratory relief was non-justiciable because they lacked a legally protectible interest in the controversy. The court found that the landowners did not have a private right of action to enforce the requirements of the incorporation code. The court concluded that the landowners' claim must be dismissed as a matter of law. View "Bleazard v. City of Erda" on Justia Law

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In Utah, a group of local citizens sponsored the incorporation of an area in Tooele County to be known as the City of Erda. After the Lieutenant Governor certified Erda’s incorporation, three landowners within Erda’s boundaries challenged the incorporation, alleging statutory violations during the incorporation process. The defendants, Erda and the Lieutenant Governor, moved to dismiss the complaint, arguing that the landowners lacked statutory standing. The district court disagreed and denied their motions to dismiss.The defendants appealed to the Supreme Court of the State of Utah, arguing that the landowners' claim for declaratory relief should be dismissed as it is non-justiciable. The Supreme Court agreed, holding that the landowners’ claim must be dismissed as a matter of law because it is non-justiciable. The court found that under Utah law, a declaratory judgment action is non-justiciable if the plaintiff lacks a protectible legal interest in the controversy. The court concluded that the landowners did not have a protectible legal interest in their claim because the legislature did not grant affected citizens a private right of action to enforce the incorporation code’s requirements. Therefore, the court reversed the district court’s decision. View "Bleazard v. Henderson" on Justia Law

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Nicholas and Julie Kuhar filed a product liability claim against Thompson Manufacturing, a Utah company, seeking compensation for injuries Nicholas sustained when his safety harness failed while he was cleaning rain gutters in New Jersey. This was not the first lawsuit the Kuhars had brought regarding this incident. They had previously sued Thompson and other defendants in New Jersey federal court, alleging that the harness was defective. That suit was unsuccessful, with Thompson being dismissed from the case due to a lack of personal jurisdiction. The Kuhars then refiled their claims against Thompson in Utah.In the New Jersey case, the Kuhars' expert witness was excluded, and the remaining defendants were granted summary judgment. Thompson then moved in the Utah case to preclude the Kuhars from litigating the issue of whether the harness was defective. The district court agreed with Thompson and dismissed the Kuhars' claims. However, the Utah Court of Appeals reversed this decision, concluding that the issue litigated and decided in New Jersey was not identical to the issue Thompson sought to preclude in Utah.The Supreme Court of the State of Utah, however, disagreed with the Court of Appeals. It concluded that the elements of issue preclusion were satisfied. The court clarified that to determine the issue-preclusive effect of the New Jersey federal court’s judgment in this case, the substantive law of New Jersey applies. Under that law, the court concluded that the issue Thompson sought to preclude the Kuhars from litigating—whether the harness was defective—was actually litigated and decided on the merits in the New Jersey court’s summary judgment order. Therefore, the Supreme Court of the State of Utah reversed the decision of the Court of Appeals. View "Kuhar v. Thompson Manufacturing" on Justia Law

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A dispute arose between SunStone Realty Partners X LLC (SunStone) and Bodell Construction Company (Bodell) over the postjudgment interest rate applied to a domesticated Hawaii judgment in Utah. Following arbitration in Hawaii over construction defects in a condominium development, SunStone obtained a judgment against Bodell exceeding $9.5 million, which it domesticated in Utah. Bodell requested the Utah court to apply Utah's lower postjudgment interest rate instead of Hawaii's higher one. SunStone opposed this, arguing that the Utah Foreign Judgment Act (UFJA) required the application of Hawaii's rate, or alternatively, that their contract or principles of comity mandated the Hawaii rate.The Supreme Court of the State of Utah affirmed the district court's decision to apply Utah's postjudgment interest rate. The court found that the UFJA, which does not specifically address postjudgment interest, instructs Utah courts to treat a foreign domesticated judgment like a Utah judgment for enforcement purposes. Since postjudgment interest serves, at least in part, as an enforcement mechanism, the UFJA requires the imposition of Utah’s postjudgment interest rate. Further, the construction contract did not require the application of the Hawaii postjudgment interest rate. The court did not consider principles of comity because the UFJA mandates a result. View "Sunstone Realty v. Bodell Construction" on Justia Law

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In this case, the Supreme Court of the State of Utah considered the appeal of Marianne Tyson who sought to access her sealed adoption records from 1978, in order to learn more about her birth parents' medical histories and any potential health risks. The district court had denied Tyson's petition, interpreting "good cause" as requiring more than a generalized desire to obtain health or genetic information unrelated to a specific medical condition of the petitioner. The district court also held that Tyson's reasons for wanting access to adoption records did not outweigh her birth mother's interest in privacy.The Supreme Court of Utah disagreed with the district court's interpretation of "good cause" and its application of the balancing test. The Supreme Court noted that the legislature did not define "good cause" in the statute and did not impose additional requirements to establish "good cause". The Court held that the district court erred in interpreting the statute to require something more than a general desire to know one's medical history. The Supreme Court also found that the district court did not properly balance the interests under the Utah Rule of Civil Procedure 107, as it focused solely on the birth mother’s privacy interests and did not consider Tyson's reasons for wanting to see her adoption records.The case was remanded back to the district court to reassess Tyson's petition under the correct standard. The district court must evaluate Tyson's petition under a correct interpretation of "good cause" and conduct a proper balancing test, giving weight to both the birth mother’s privacy interests and Tyson's reasons for wanting to see her adoption records. View "In re Adoption of M.A." on Justia Law

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In the medical malpractice case concerning the withdrawal of life-sustaining treatment from Lillian Birt, her daughter Jenafer Meeks sued the treating doctors, Wei Peng and Christina G. Richards, both individually and on behalf of Ms. Birt's heirs and estate. The children of Ms. Birt had decided to discontinue her life support based on the misinformation they received from the doctors about her condition. The doctors inaccurately portrayed her condition as terminal, leading the children to believe that the treatment was only prolonging her life unnaturally. However, Ms. Birt's condition was not terminal, and there was a high probability of her recovery if the treatment had continued.In the Supreme Court of the State of Utah, the doctors appealed on two issues. Firstly, they argued that the trial court's jury instruction 23 was incorrect as it did not explicitly state that Ms. Meeks had the burden to prove the standard of care. Secondly, they contended that the lower court erred in denying their motion for judgment as a matter of law on the survival claim due to lack of evidence that Ms. Birt experienced pain and suffering in the hours between the doctors' negligence and her death.The Supreme Court held that the trial court correctly instructed the jury that Ms. Meeks had the burden to prove the standard of care, as the instruction implicitly required the jury to determine the standard of care as part of proving a breach of it. However, the Supreme Court agreed with the doctors that Ms. Meeks failed to provide evidence of Ms. Birt's experience of pain, suffering, or inconvenience during the period between the doctors' negligence and her death. Therefore, the Supreme Court affirmed in part and reversed in part the decision of the lower court. View "Peng v. Meeks" on Justia Law

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In this case, Cathy McKitrick, an investigative journalist, sought access to certain records under the Government Records Access and Management Act (GRAMA). The Ogden City Records Review Board ordered the city to release redacted versions of the records. Kerry Gibson, the subject of the records, petitioned the district court to prevent their release. McKitrick intervened in the proceedings and moved to dismiss Gibson's petition for lack of standing. The Supreme Court of the State of Utah held that Gibson lacked standing. Before the district court dismissed the case, McKitrick moved for an award of attorney fees and litigation costs, which was denied by the district court. On appeal, the Supreme Court of the State of Utah reversed the district court’s interpretation of the fee provision but did not hold that McKitrick was entitled to a fee award. Because the district court did not consider substantive aspects of the fee provision, the Supreme Court remanded the case for it to do so. View "McKitrick v. Gibson" on Justia Law

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In this appeal arising from a dispute between lien holders regarding the distribution of the money a foreclosure sale of Zermatt Resort had generated the Supreme Court vacated the decision of the court of appeals concluding that it had jurisdiction to resolve a procedural matter and affirming the district court, holding that the court of appeals did not have jurisdiction to resolve the matter.After the district court entered its final judgment in this matter but before the time to appeal expired Trapnell & Associates, LLC purchase the plaintiff's interest in the litigation. Trapnell filed a notice under Utah R. Civ. P. 17 that it was a real party in interest and, on that same day, lodged a notice of appeal. The court of appeals noted that it would have been better had Trapnell filed a motion invoking Utah R. Civ. P. 25(c) instead of a notice invoking rule 17 but ruled on the merits of Trapnell's arguments, concluding that because Trapnell had intended to become a party and the district court had treated Trapnell as a party, Trapnell had become a party. The Supreme Court vacated the court of appeals' decision, holding that the court of appeals erred in concluding that Trapnell had properly substituted into this matter. View "Trapnell & Associates, LLC v. Legacy Resorts, LLC" on Justia Law

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The Supreme Court affirmed the ruling of the district court that Plaintiff's post-judgment motion was timely, holding that the district court's order of dismissal did not constitute a separate judgment under Utah R. Civ. P. 58A(1), and therefore, the judgment was not complete and entered until 150 days after the clerk recorded the order of dismissal.This appeal stemmed from a legal malpractice claim. The district court dismissed the complaint. On April 10, the district court signed the proposed order of dismissal with prejudice. On May 9, Plaintiff filed a post-judgment motion requesting various forms of relief. Defendant argued that the motion was untimely because it was filed more than twenty-eight days after the April 10 order. The district court granted Plaintiff's motion and vacated the April 10 order, concluding that the order was not a separate judgment under Rule 58A(a) and therefore did not start the time to file post-judgment motions. The Supreme Court affirmed, holding (1) the district court did not err in concluding that the April 10 order was not a separate judgment pursuant to Rule 58A(a); and (2) because the April 10 order did not constitute an "entry of judgment" that started the time to file post-judgment motions, Plaintiff's post-judgment motion was timely. View "Griffin v. Snow Christensen & Martineau" on Justia Law