Utah Supreme Court

The court reversed the award of a contingency-fee component of attorney-fee damages because the Walkers failed to disclose that component under rule 26 and failed to prove its foreseeability and amount at trial.

The court held that “legal justification” in Utah’s special-mitigation statute is a term of art referring to conduct classified as justified under the criminal code and common-law distinction between justification and excuse.

The court held that Darden waived its limitations defense by failing to request relief based on the workers’ compensation notice requirement, even though it pleaded the defense and introduced evidence that could have supported it.

The Utah Supreme Court declined to disturb the Labor Commission’s order awarding Robyn Young permanent total disability benefits and denying Granite School District a subrogation offset.

The court affirmed Castillo’s convictions for four counts of aggravated sexual abuse of a child and one count of rape of a child. It held that Castillo waived most of his rule 702 challenges, and that his remaining ineffective-assistance claims failed because counsel’s trial choices were objectively reasonable.

The Utah Supreme Court affirmed the district court's dismissal of Oscar Nunez's amended post-conviction petition as untimely. The court held that rule 65C(h)(3) of the Utah Rules of Civil Procedure does not supersede rule 15(c)'s relation-back test, that Patterson v. State did not overrule Noor v.

The court held that it could review the mother's timely appeal from the post-remand termination order, even though her first appeal was untimely and the intermediate appellate court's jurisdiction had not been expressly resolved.

The Utah Supreme Court denied George Adams' petition for extraordinary relief challenging the justice court's refusal to accept his guilty plea to a DUI charge without prosecutorial consent under Utah Code section 41-6a-513.

The Utah Supreme Court held that termination of parental rights under the Adoption Act's Termination Provision, Utah Code subsection 81-13-205(5)(e), requires a strictly necessary analysis, because the Adoption Act's reference to grounds 'described in' the Termination Act incorporates the qualifying strictly necessary…

The Utah Supreme Court affirmed the termination of Father's parental rights to his four children to facilitate their adoption by Stepfather. Consistent with its recent companion precedent, the court held that termination under Utah Code subsection 81-13-205(5)(e) of the Utah Adoption Act is subject to the strictly…

The Utah Supreme Court affirmed the court of appeals' holding that Abu-Ulba's Note Theory of damages was unpreserved. Although a district court's sua sponte consideration of an issue can preserve it for appeal, the court held that such consideration must serve the preservation principles of judicial economy and…

The Utah Supreme Court reversed a district court's order suppressing evidence seized when police executed two daytime-only search warrants at night. Under State v. Fixel and State v.

The Utah Supreme Court held that the term 'award' in the Dramshop Act's contribution provision, Utah Code section 32B-15-302(1)(a), read in context, does not include amounts voluntarily paid pursuant to a settlement agreement, so bars that settled an injured driver's dramshop claims could not pursue contribution…

The Utah Supreme Court held that the Juvenile Code does not prohibit a prosecutor from filing a delinquency petition after a juvenile probation officer has improperly offered a nonjudicial adjustment on a referral that objectively involves a felony; eligibility for a nonjudicial adjustment turns on an objective…

The court held that dismissal is not an available sanction when an employee obstructs an independent medical examination in a workers’ compensation proceeding because the governing statute specifically prescribes suspension during the period of refusal or obstruction.

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 Utah Supreme Court reversed the court of appeals and reinstated Ray’s forcible-sexual-abuse conviction, holding that trial counsel was not constitutionally deficient for failing to object to an undefined “indecent liberties” term in the jury instruction.

The court held that the court of appeals could not determine whether Scott received ineffective assistance without knowing the content and context of the excluded threat. The absence of that evidence also prevented a determination of prejudice under the applicable ineffective-assistance framework.

The court reversed the court of appeals because it improperly reviewed a jury-instruction issue that was neither preserved at trial nor raised on appeal. It held that invited error, the absence of ineffective-assistance briefing, and mere oversight by trial counsel did not establish a valid exception to preservation…

The Utah Supreme Court held that tortious interference with economic relations cannot be established solely by proof of an improper purpose; the plaintiff must prove interference by improper means.

The court affirmed dismissal of all of America West Bank Members’ claims, holding that the complaint failed to plead the essential facts supporting its contract, good-faith, and takings theories.

The court affirmed Nielsen's aggravated-murder and desecration-of-a-body convictions and his life-without-parole sentence, but vacated the kidnapping and aggravated-kidnapping convictions because those offenses merged.

The court rejected all claims challenging Maestas's convictions and death sentence, including challenges to jury selection, jury communications, expert testimony, prosecutorial comments, and the sufficiency of the evidence.

The Utah Supreme Court reversed summary judgment invalidating an amendment to a revocable trust that removed Ron Patterson as a beneficiary. It held that the Utah Uniform Trust Code superseded the prior strict-compliance rule and permitted the amendment because the trust did not make its specified amendment method…

The court held that the eminent-domain statute does not authorize condemnation of private land to build a road accessing leased oil and gas deposits. Because the phrase "mineral deposits" has two reasonable interpretations and the statute therefore is ambiguous, the court strictly construed the ambiguity against the…

The Utah Supreme Court dismissed the victims' appeal because, at the time the appeal was filed, no statute granted crime victims a right to appeal, and the court will not apply a later‑enacted statute retroactively.

The Utah Supreme Court affirmed in part and reversed in part a district court's rule 12(b)(6) dismissals in a homeowner association's construction-defect suit arising from water intrusion, latent defects, and soil subsidence in a 145-unit planned unit development.

The Utah Supreme Court affirmed a juvenile court order terminating reunification services and changing twelve-year-old K.F.'s permanency goal from reunification with her mother to individualized permanency (long-term foster care) with a secondary goal of custody and guardianship.

The court held that Giusti's appeal was timely because the appeal period began when the required separate judgment was entered, not when the earlier final order was issued. It affirmed summary judgment for SWC on Giusti's contract, fraudulent inducement, and tortious interference claims, concluding that his employment…

The Utah Supreme Court affirmed the district court’s grant of summary judgment on all of Oman’s claims, finding the District’s termination was proper under the Classified Agreement and the Utah Orderly School Termination Procedures Act, and that Oman failed to state viable claims for breach of contract, good‑faith…

The Utah Supreme Court affirmed dismissal of Paul Allen's post-conviction petition because his appeal failed to identify errors in the district court's ruling, inadequately briefed the issues, and omitted essential portions of the record.

The Utah Supreme Court affirmed directed verdicts rejecting Daines's claims arising from an alleged oral promise of ownership shares in a surgical center. It held that the signed Release was an integrated and unambiguous agreement that released ASC from all claims connected to the center's organization, development…

The Utah Supreme Court affirmed Jennete Killpack’s conviction for child abuse homicide and her one‑to‑fifteen‑year prison sentence, holding that the jury instruction on recklessness was proper, the proposed instructions on reasonable parental choices and medical treatment were correctly rejected, the admission of…

The Utah Supreme Court affirmed that the lease is a valid, integrated, and unambiguous contract and held that extrinsic evidence of a separate oral agreement is not admissible to challenge integration when the lease contains a clear integration clause.

The court held that a summary-judgment movant who relies on judicial estoppel, an issue on which the movant would bear the burden at trial, must affirmatively establish the doctrine's essential elements and show that no material factual dispute remains.

The Utah Supreme Court held that the juvenile court permissibly used the clear-and-convincing-evidence standard when making factual findings at the permanency hearing, even though the governing statute required only a preponderance of the evidence.

On certiorari, the Utah Supreme Court held that the invited error doctrine did not bar the Pratts' challenge to the judicial proceeding privilege ruling, because their late responsive memorandum was not an affirmative representation leading the trial court into error.

The court held that the court of appeals applied the wrong standard when reviewing the Commission's factual determinations about Martinez's ability to perform the essential functions of prior work and the availability of other work.

The Utah Supreme Court held that appellate review of a trial court’s custodial-interrogation determination under the Fifth Amendment is for correctness rather than abuse of discretion.

The Utah Supreme Court affirmed Winfield's aggravated-robbery conviction without reaching the merits of either appellate claim. It held that Winfield invited any voir-dire error by affirmatively accepting the jury panel and that he failed to preserve his insufficiency-of-the-evidence claim because neither his pretrial…