Utah Case Summaries
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Utah

UtahCriminalCriminal Proceduredomestic-violence
Court of Appeals of Utah
Uncategorized

Bluffdale City v. Verive — Brief Physical Impediment of a Preferred Exit Satisfies Utah’s Unlawful Detention Statute

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The Utah Court of Appeals affirmed Aaron Verive’s four class B misdemeanor convictions for unlawful detention and domestic violence in the presence of a child, holding that momentarily blocking a preferred exit—whether a doorway or a vehicle—satisfies the unlawful detention statute regardless of duration or alternative routes, and that events immediately following the charged acts were intrinsic evidence outside Rule 404(b)’s other-acts exclusion.

UtahMunicipal LawReal EstateReal Property
Court of Appeals of Utah
Uncategorized

Johnson v. Moab City — Utah’s 1886 Townsite Plat Vested Title Before the 1890 Federal Patent, Defeating a Century-Long Adverse Possession Claim

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The Utah Court of Appeals reversed a partial summary judgment that had quieted most of a disputed downtown Moab parcel to a private landowner, holding that the 1886 Moab Townsite Plat vested title in the municipality before the 1890 federal Luster Patent issued, that Utah’s rebuttable presumption of official regularity supplies the missing historical documentation, and that adverse possession cannot run against government land designated for public use regardless of how long the private use has continued.

UtahContract InterpretationFamily Law
Court of Appeals of Utah
Uncategorized

Schmidt v. Schmidt — Three Plausible Interpretations of a Divorce Mortgage-Payment Provision Compel Remand for an Evidentiary Hearing

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The Utah Court of Appeals reversed a district court’s order enforcing a post-divorce mortgage-payment obligation, holding that Provision 2 of the parties’ Modification supports at least three reasonable interpretations—property-specific, region-limited, and location-neutral—and is therefore ambiguous as a matter of law, requiring remand for an evidentiary hearing on the parties’ intent before the provision can be enforced against Stephen Schmidt.

UtahCriminalCriminal ProcedureEvidence
Court of Appeals of Utah
Uncategorized

State v. Talbert — Utah Court of Appeals Rejects Variance, Rule 404(b), and Ineffective-Assistance Challenges to Sexual Abuse Convictions

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The Utah Court of Appeals affirmed six sexual-abuse convictions, holding that uncharged grooming conduct is admissible as intrinsic evidence outside Rule 404(b), that a charging variance between the information and the acts proven at trial raises sufficiency and notice issues—not jurisdictional ones—and that failure to seek a trial continuance upon discovering the variance waives procedural-due-process claims.

UtahCriminalCriminal ProcedureEvidence
Court of Appeals of Utah
Uncategorized

State v. Kent — Utah Court of Appeals Affirms Enticement Conviction Despite Undercover Officer’s Adult Photos and Voice

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The Utah Court of Appeals affirmed a child enticement conviction, holding that the sufficiency-of-evidence inquiry is subjective—asking whether this defendant believed the persona was a minor—and that entrapment as a matter of law requires more than a realistic undercover persona; here, the defendant’s own texts and statements showed actual knowledge of the victim’s age and independent criminal initiative.

UtahInsurance CoverageInsurance LawPersonal Injury & Tort
Court of Appeals of Utah
Uncategorized

Newman v. LM General Insurance — UIM Bad Faith Claim Fails Where General Damages Valuation Is Fairly Debatable as a Matter of Law

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The Utah Court of Appeals affirmed summary judgment for LM General Insurance on an alternative basis—that an insured’s underinsured motorist claim was fairly debatable as a matter of law—because the insurer diligently investigated, made a timely offer that fairly reflected the inherent uncertainty of general damages, and acted promptly throughout, even though the arbitrator ultimately awarded significantly more.

UtahAppellate ProcedureFamily LawOrders of Protection
Court of Appeals of Utah
Uncategorized

Canteros-Alvarez v. Green — Conditional Text Threat Does Not Establish Imminent Physical Harm Under Utah’s Cohabitant Abuse Act

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The Utah Court of Appeals vacated a protective order against a sister whose angry text—expressing a conditional desire to fight—did not place the petitioner in reasonable fear of imminent physical harm under the Cohabitant Abuse Act, because the threatened violence was contingent on a future event, the parties were physically distant, and there was no history of violence between them.

UtahAppellate ProcedureCriminalIneffective Assistance of Counsel
Court of Appeals of Utah
Uncategorized

State v. Perez — Jurors’ Brief Hands in Voir Dire Did Not Compel For-Cause Removal; Ineffective Assistance Claim Fails

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The Utah Court of Appeals affirmed convictions for aggravated burglary and related charges, holding that trial counsel was not ineffective in declining to challenge for cause three jurors who raised their hands to leading voir dire questions and then affirmed their ability to follow jury instructions in response to the prosecutor’s follow-up.

UtahCriminalRestitution
Court of Appeals of Utah
Uncategorized

State v. Curwick — Medical Evidence Plus UOVC Documentation Suffices to Establish Restitution Causation for Victim’s Mother

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The Utah Court of Appeals affirmed a restitution order for an aggravated kidnapping victim’s mother, holding that a medical form attributing her PTSD to the crime, her own written statements, and a UOVC restitution specialist’s declaration—taken together—provided sufficient evidence of proximate causation for her lost wages.

UtahCriminalIneffective Assistance of CounselPost-Conviction Relief
Court of Appeals of Utah
Uncategorized

Miranda v. State — Post-Conviction Court Erroneously Presumed Prejudice From Unanimity Instruction Failure; Convictions Reinstated

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The Utah Court of Appeals reversed a grant of post-conviction relief, holding that the post-conviction court improperly applied the Chadwick presumption of prejudice to an ineffective-assistance claim; under Strickland, Miranda failed to show a reasonable probability that a proper unanimity instruction would have changed the verdict.

UtahCivil ProcedureFiduciary DutyLegal Malpractice
Court of Appeals of Utah
Uncategorized

GeoMetWatch v. Durham Jones & Pinegar — Prior Federal Defeat Bars Legal Malpractice Claims Under Issue Preclusion

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The Utah Court of Appeals affirmed summary judgment for a law firm on all legal malpractice claims, holding that issue preclusion arising from prior Tenth Circuit litigation conclusively barred GMW’s lost-profits theories and that GMW’s lost business value theory failed for lack of nonspeculative causation evidence.

UtahCriminalEvidenceIneffective Assistance of Counsel
Court of Appeals of Utah
Uncategorized

State v. Collard — Convictions Reversed After Counsel Failed to Redact Domestic-Violence Finding from Protective Order Exhibit

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The Utah Court of Appeals affirmed denial of a motion to arrest judgment on protective-order-violation convictions — holding that the State sufficiently proved the permanent order’s terms through testimony and a docket entry — but reversed all three convictions on ineffective-assistance grounds because defense counsel failed to seek redaction of a domestic-violence finding in the temporary protective order admitted as a trial exhibit, a finding the court had already ruled irrelevant and whose admission undermined confidence in the verdict.

UtahFamily LawIneffective Assistance of CounselJuvenile Law
Court of Appeals of Utah
Uncategorized

In re A.H. — Utah Court of Appeals Again Vacates TPR Order After Finding All Three of Father’s Trial Attorneys Rendered Ineffective Assistance

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For the third time, the Utah Court of Appeals vacated an order terminating Father’s parental rights as to two young children, holding that all three of his trial attorneys — retained counsel and two appointed counsel — rendered ineffective assistance by failing to file pretrial disclosures and seek a continuance, depriving Father of the ability to call sibling witnesses whose testimony bore directly on the best-interest determination; the court also held that Utah’s IAC right extends to retained attorneys who never formally enter an appearance.

UtahCivil ProcedureEvidencePersonal Injury & Tort
Court of Appeals of Utah
Uncategorized

Holmes v. Smith — New Trial Ordered After Collateral Source Misrule and Improperly Admitted Medical Records

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The Utah Court of Appeals reversed an automobile accident verdict and remanded for a new trial after the trial court misapplied the collateral source rule by excluding evidence of employer-provided workplace accommodations, admitted medical records without proper business-records foundation under Utah R. Evid. 803(6), and improperly excluded life care planner testimony on work-life expectancy based on inconsistencies that went to weight rather than admissibility.

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