Justia Injury Law Opinion SummariesArticles Posted in Utah Supreme Court
Sheppard v. Geneva Rock
The Supreme Court reversed the district court granting Defendant's renewed motion for judgment as a matter of law and vacating the jury's general damages verdict in favor of Plaintiff on her negligence claim, holding that the district court erred.Plaintiff's vehicle was hit by a truck by a driver that worked for Geneva Rock. Plaintiff sued the driver and Geneva Rock, alleging that the driver's negligence caused the crash and that Geneva Rock had negligently employed the driver. Geneva Rock conceded that its driver was at fault for the collision. After Plaintiff rested her case-in-chief during a trial on the issue of damages, the court ruled that the jury could not award special damages to Plaintiff for lack of sufficient evidence. The jury returned a general damages verdict of $30,000. The district court vacated the jury's verdict, concluding that Plaintiff failed to produce sufficient evidence to meet the requirements of Utah Code 31A-22-309. The Supreme Court reversed and remanded the case, holding (1) Plaintiff was entitled to ask the jury to award special damages; and (2) the district court improperly excluded evidence of Geneva Rock's negligent hiring practices. View "Sheppard v. Geneva Rock" on Justia Law
Ramon v. Nebo School District
The Supreme Court reversed the judgment of the district court granting judgment on the pleadings in favor of Nebo School District on Plaintiff's negligent employment claim, holding that the district court erred in dismissing Plaintiff's negligent employment claim.A school bus operated by a driver employed by Nebo School District caused a crash with Plaintiff. In his complaint, Plaintiff claimed that Nebo was liable for its driver's negligence under principles of respondent superior and that Nebo was independently negligent because it continued to employ the driver even though he had been involved in several accidents. Nebo moved for judgment on the pleadings, arguing that the negligent employment claim was redundant with the negligence claim and that Plaintiff was not entitled to pursue a claim directly against it after it conceded vicarious liability. The district court granted the motion. The Supreme Court reversed, holding that the district court (1) did not abuse its discretion when it found that Nebo's motion for judgment on the pleadings was timely; and (2) Plaintiff was entitled to proceed on alternate claims. View "Ramon v. Nebo School District" on Justia Law
Ragsdale v. Fishler
The Supreme Court reversed in part and vacated in part the judgment of the district court denying Plaintiff's request for a civil stalking injunction against Defendant, holding that the district court erred.Plaintiff ran a residential treatment program for young woman. Defendant, her neighbor, objected to the program's presence in his neighborhood and flipped off and swore at Plaintiff and the program attendees and placed provocative signs in his yard. Plaintiff sought a civil talking injunction, which the district court denied. The Supreme Court reversed in part and vacated in part, holding (1) the district court misinterpreted the stalking statute; (2) the district court failed to assess the impact of Defendant's conduct on a reasonable person in Plaintiff's circumstances; (3) the district court applied an incorrect analysis in deciding that the First Amendment protected Defendant's conduct; and (4) because the reversal of the first three issues may affect the basis for the district court's attorney-fees decision, that decision is vacated, and the matter is remanded for a new determination. View "Ragsdale v. Fishler" on Justia Law
Scott v. Wingate Wilderness Therapy, LLC
The Supreme Court answered a certified question posed by the United States Court of Appeals for the Tenth Circuit regarding the reach of the Utah Health Care Malpractice Act (Act), Utah Code 78B-3-401 through 426, by concluding that the Act applied in this case involving an injury sustained while climbing a rock formation during a "wilderness therapy" excursion.Jacob Scott sued Wingate Wilderness Therapy, LLC seeking relief for injuries he sustained as a minor while rock climbing during a wilderness therapy hiking excursion. The federal district court granted Wingate's motion to dismiss, concluding that the Act applied to Scott's claims and that Scott (1) failed to file his action within the two-year statute of limitations, and (2) failed to comply with the Act's procedural requirements. Scott appealed, arguing that the district court erred in finding that his injuries arose out of the health care provided by Wingate. The circuit court certified a question to the Utah Supreme Court, which answered by holding that, under the circumstances of this case, the Act applied to Scott's claims. View "Scott v. Wingate Wilderness Therapy, LLC" on Justia Law
In re Estate of D.A. Osguthorpe, D.V.M.
The Supreme Court affirmed in part and reversed in part the judgment of the district court in this trust and estate dispute, holding that, under certain circumstances, a party may assert a claim for intentional interference with inheritance.A dozen years after the decedent's death, his children sued David Rudd - the attorney who represented the decedent in various matters - and Ballard Spahr, LLP - the law firm where Rudd was a partner - claiming that Defendants improperly influenced the decedent to amend his will and trust in a way that shifted a portion of the children's expected inheritance to other beneficiaries, engaged in improper and/or misleading conduct, and mishandled estate assets after the decedent's death. On appeal were the district court's grant of (1) Defendants' motion to dismiss the children's claim for intentional interference with inheritance, (2) summary judgment on several tort claims the children wanted to assert on behalf of the decedent's estate, and (3) a motion in limine preventing the children from impeaching Rudd with certain statements. The Supreme Court held that the district court (1) erred in dismissing the intentional interference with inheritance claim; (2) did not err by not assigning the estate's claims to the children; and (3) erred in granting the motion in limine. View "In re Estate of D.A. Osguthorpe, D.V.M." on Justia Law
Shree Ganesh, LLC v. Weston Logan, Inc.
The Supreme Court reversed the judgment of the district court dismissing Shree Ganesh, LLC's contract and tort claims against Weston Logan, Inc., and Matthew Weston, an individual, holding that there remained a genuine dispute as to material facts, precluding summary judgment.Shree Ganesh entered into a contract with Weston Logan to purchase Weston Logan's Best Western Inn. After the sale of the property closed, Shree Ganesh learned about Weston Logan's plans to build a competing hotel across the street. Shree Ganesh subsequently sued Weston Logan for its failure to disclose its plans to develop the competing hotel. The district court granted summary judgment in favor of Weston Logan on all claims. The Supreme Court reversed, holding (1) the purchase agreement was ambiguous as to Weston Logan's disclosure obligations; and (2) there remained a genuine dispute as to material facts relevant to Shree Ganesh's tort claims. View "Shree Ganesh, LLC v. Weston Logan, Inc." on Justia Law
Williams v. Kingdom Hall of Jehovah’s Witnesses
The Supreme Court vacated the decision of the district court concluding that the adjudication of Plaintiff's intentional infliction of emotional distress claim against a church must be dismissed on the grounds that the adjudication of this claim would violate the Establishment Clause of the First Amendment, holding that recent changes in the Supreme Court's Establishment Clause jurisprudence required further development of the facts and legal arguments presented in this case.Plaintiff and her family attended the Roy Congregation of the Jehovah's Witnesses Church. When Plaintiff was sexually assaulted by another Jehovah's Witnesses congregant the Church investigated Plaintiff to determine whether she had engaged in the sin of "porneia." During the investigation, four Elders in the Church convened a disciplinary hearing in which they played an audio recording of the other congregant raping Plaintiff. Plaintiff then filed her complaint against the Church for intentional or negligent infliction of emotional distress. The district court dismissed the complaint, concluding that the Establishment Clause barred the claim. The Supreme Court vacated the district court's decision, holding that because the district court relied on a test that has recently been displaced by the Supreme Court, the case must be remanded for additional proceedings. View "Williams v. Kingdom Hall of Jehovah's Witnesses" on Justia Law
Feldman v. Salt Lake City Corp.
The Supreme Court reversed the judgment of the district court dismissing this wrongful death suit against Salt Lake City on the grounds that the action was barred by Utah's Limitations on Landowner Liability Act's prohibition on claims for personal injury caused by the inherent risks of participating in an activity with a recreational purpose, holding that Plaintiffs sufficiently alleged that the death in this case was not caused by a risk inherent in a recreational activity.Liudmila Feldman drowned in a creek at a City park when walking her dogs. Feldman tried to get the dogs out of the creek within the park but was caught in a dangerous current and drowned. Plaintiffs sued the City for wrongful death and other causes of action, asserting that the dangerous current at the creek resulted from manmade developments. The district court granted the City's motion to dismiss, concluding that Utah Code 57-14-401 barred Plaintiffs' claims. The Supreme Court reversed, holding (1) the district court correctly held that application of section 401 does not violate the wrongful death clause of the Utah Constitution; but (2) Plaintiffs sufficiently alleged that Feldman's death was not caused by an inherent risk in her recreational activity of walking in the park with her dogs. View "Feldman v. Salt Lake City Corp." on Justia Law
Luna v. Luna
The Supreme Court reversed the decision of the court of appeals affirming the order of the district court granting summary judgment in favor of Maria Luna on Luis Luna's negligence claim, holding that the court of appeals improperly adopted the judicial admission doctrine as applied to a party's deposition testimony.Luis was a passenger in his sister Maria's car when it collided with a vehicle driven by Antonio Arias in a Salt Lake City intersection. Luis sued Maria and Antonio. Maria moved for summary judgment based in part on Luis's testimony that Maria had entered the intersection on a green light. Luis sought to introduce Antonio's testimony that he had the green light, but the district court refused to allow Luis to create a genuine issue of material fact by introducing evidence contradicting his own sworn deposition testimony. The district court granted summary judgment for Maria. The court of appeals affirmed, concluding that Luis's statement should be considered a judicial admission not capable of being rebutted by other evidence. The Supreme Court reversed and remanded the case for further proceedings, holding that a party's deposition testimony is like any other evidentiary admission and can be contradicted with other credible evidence. View "Luna v. Luna" on Justia Law
Arreguin-Leon v. Hadco Construction, LLC
The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the district court in favor of Plaintiff in this personal injury action, holding that the district court abused its discretion in allowing Plaintiff's expert witness to offer undisclosed causation testimony, and the error was harmful.Plaintiff, who was injured while working on a highway construction site, sued the general contractor for failing to take necessary safety measures to protect workers from highway traffic. The jury found that the general contractor was partially liable for Plaintiff's injury. On appeal, the general contractor argued that the district court erred when it allowed Plaintiff's expert witness to offer an undisclosed opinion on causation. The court of appeals agreed, determining that the error was harmful enough to warrant reversal and a new trial. The Supreme Court affirmed, holding that the testimony was erroneously admitted and that the error was not harmless. View "Arreguin-Leon v. Hadco Construction, LLC" on Justia Law