Utah Supreme Court
RMB v. Celotto
July 23, 20262026 UT 19
Summary
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 against the allegedly intoxicated driver. The court rejected the bars' common law incorporation argument because they identified no precise principle recognized in Utah, and it declined to reach their absurdity-based policy argument as untimely, holding in the alternative that it failed under the doctrine's narrow, exacting standard. The court of appeals' affirmance of summary judgment dismissing the contribution crossclaims was affirmed.