McCaffrey v. Anderson

Summary

The Utah Supreme Court reversed the district court’s summary judgment ruling and held that the municipal-incorporation code’s differing exclusion rights for landowners added before and after the first public hearing satisfy rational-basis review under the Uniform Operation of Laws Clause. The cutoff is reasonably related to legitimate objectives including finality, protection of landowners, and preventing endless boundary changes. The court declined to decide the Landowners’ alternative argument based on the original meaning of the clause because it was not decided below, was insufficiently developed for appellate review, and involved unsettled law.