Justia Constitutional Law Opinion Summaries

Attorneys in Utah representing injured workers in workers’ compensation claims receive their fees out of the compensation awarded to the worker. IWA challenged the statute delegating the authority to regulate these fees to the Labor Commission and the Labor Commission's fee schedule. The court held that the regulation of attorney fees is included within the power to govern the practice of law. Because the Utah Supreme Court is vested with exclusive inherent and constitutional authority to govern the practice of law - and the court cannot under the separation-of-powers doctrine delegate the regulation of attorney fees to the legislature or the Commission - the court held the Commission’s fee schedule and its authorizing statute unconstitutional. The court declined to enact a fee schedule regulating the fees of injured workers' attorneys at this time. View "Injured Workers Ass'n of Utah v. State" on Justia Law

Plaintiff ClearOne is a Utah corporation and Defendant Revolabs is a competitor incorporated in Delaware with its principal place of business in Massachusetts. The underlying dispute arose when Revolabs recruited and hired Timothy Mackie while he was still employed by ClearOne. ClearOne brought this suit in Utah district court, alleging intentional interference with a contractual relationship, predatory hiring, and aiding and abetting a breach of fiduciary duty. Revolabs filed a motion to dismiss for lack of personal jurisdiction. The trial court granted the motion. The Supreme Court affirmed, holding (1) ClearOne failed to allege that Revolabs had sufficient minimum contacts to subject it to specific personal jurisdiction in Utah; and (2) the trial court did not abuse its discretion in denying discovery to determine whether Revolabs was subject to general personal jurisdiction in Utah. View "ClearOne, Inc. v. Revolabs, Inc." on Justia Law

Salt Lake City Corp. used its power of eminent domain to condemn land owned by Evans Development Group, LLC in order to exchange the property for another piece of property owned by Rocky Mountain Power. The City filed a complaint asserting several public uses and public purposes for the condemnation. Evans moved for summary judgment, arguing that the City lacked statutory authority to condemn its property because the condemnation was not for a public use as required by Utah Code 78B-6-501. The City filed a cross-motion for partial summary judgment as to the issue of public use. The district court granted summary judgment in favor of the City. The Supreme Court reversed, holding that although a property exchange may not be completely prohibited by the relevant eminent domain statutes, it may not be accomplished in the manner attempted in this case. View "Salt Lake City Corp. v. Evans Dev. Group, LLC" on Justia Law

Salt Lake City Corp. used its power of eminent domain to condemn land owned by Evans Development Group, LLC in order to exchange the property for another piece of property owned by Rocky Mountain Power. The City filed a complaint asserting several public uses and public purposes for the condemnation. Evans moved for summary judgment, arguing that the City lacked statutory authority to condemn its property because the condemnation was not for a public use as required by Utah Code 78B-6-501. The City filed a cross-motion for partial summary judgment as to the issue of public use. The district court granted summary judgment in favor of the City. The Supreme Court reversed, holding that although a property exchange may not be completely prohibited by the relevant eminent domain statutes, it may not be accomplished in the manner attempted in this case. View "Salt Lake City Corp. v. Evans Dev. Group, LLC" on Justia Law

Petitioners, as members of Utah Term Limits NOW!, sponsored an initiative application in which Petitioners sought to initiate legislation imposing term limits on persons appointed by the Governor to state boards and commissions. The Lieutenant Governor rejected the initiative application. Petitioners filed a petition for extraordinary writ asking the Supreme Court to compel the Lieutenant Governor to rescind and withdraw his rejection of Petitioners’ application. After filing their petition, Petitioners ceased efforts to place the proposed initiative on the ballot. Thereafter, the Lieutenant Governor filed a suggestion of mootness. In response, Petitioners asked the Court to resolve the issues based on the “public interest” exception to the mootness doctrine. The Supreme Court dismissed the petition for extraordinary writ as moot and held that the public interest exception to the mootness doctrine did not apply in this case. View "Poulton v. Cox" on Justia Law

Monsour Al Shammari, a citizen of Saudia Arabia, was arrested and charged with rape. The Royal Consulate of Saudia Arabia provided the cash funds to post bail. Al Shammari subsequently attempted to cross the border into Mexico but was detained by the United States Customs and Border Patrol. Thereafter, Al Shammari failed to appear for a scheduled hearing, and the district court ordered the cash bail forfeited. Al Shammari moved to set aside the order of forfeiture, contending that the forfeiture was procedurally deficient because the Consulate was not given notice. The district court ordered the bail forfeited, concluding that the Consulate was not a “surety” for purposes of Chapters 20 and 20b of Title 77 of the Utah Code. The Supreme Court denied the Consulate’s petition for extraordinary relief, concluding that the Consulate was not a surety that was constitutionally or statutorily entitled to notice. View "Royal Consulate v. Hon. Pullen" on Justia Law

Utah’s pay-TV sales tax scheme provides a sales tax credit for an amount equal to fifty percent of the franchise fees paid by pay-TV providers to local municipalities for use of their public rights-of-way. Satellite providers, however, use a different business model that does not trigger franchise fees. The satellite providers brought this lawsuit asserting that Utah’s tax scheme favors local economic interests at the expense of interstate commerce in violation of the Commerce Clause and the Uniform Operation of Laws Clause. The State Tax Commission moved for judgment on the pleadings. The district court granted the motion. The Supreme Court affirmed, holding (1) Utah’s pay-TV tax credit survives dormant commerce scrutiny; and (2) the tax credit survives rational basis scrutiny under the Uniform Operation of Laws Clause. View "DIRECTV v. Utah State Tax Comm’n" on Justia Law

Defendant was parked on the side of a highway with his hazard lights flashing when two sheriff’s deputies stopped to check on his welfare. The officers subsequently discovered marijuana in Defendant’s vehicle. The State charged Defendant with possession of marijuana and possession of drug paraphernalia. Defendant moved to suppress the evidence obtained from his vehicle. The district court denied the motion to suppress, ruling that the stop was justified by the community caretaking doctrine. After a jury trial, Defendant was convicted of the charges. Defendant appealed the denial of his motion to suppress. The Supreme Court affirmed, holding (1) the deputies seized Defendant when they pulled behind his parked vehicle with blue and red lights flashing; but (2) the community caretaking doctrine justified the stop under the facts of this case, and therefore, the seizure did not violate the Fourth Amendment. View "State v. Anderson" on Justia Law

In 2002, Appellant, a Mexican native and a lawful permanent resident of the United States, pleaded guilty to felony theft. Eight years later, deportation proceedings were initiated against Appellant, in part due to Appellant’s 2002 felony theft conviction. Appellant filed a petition asking the district court to vacate his 2002 plea under the Utah Post-Conviction Remedies Act (PCRA) or, alternatively, through a writ of coram nobis. In his petition, Appellant claimed that his counsel was ineffective during the plea process by failing to disclose the possible immigration consequences related to his plea. The district court dismissed Appellant’s petition and writ of coram nobis, concluding (1) Appellant’s petition was time barred by the PCRA, and (2) Appellant was not deprived of effective assistance of counsel, as Appellant knew or should have known that there were potential immigration consequences related to his plea. The Supreme Court affirmed, holding (1) Appellant failed to preserve his argument that his attorney affirmatively misrepresented the immigration consequences of his plea; and (2) the district court did not err in denying Appellant’s petition for a writ of coram nobis, as Appellant had a remedy available to him through the PCRA. View "Oseguera v. State" on Justia Law

After law enforcement officers discovered child pornography on Defendant’s computer, they applied for and obtained a federal search warrant to search the computer. Defendant subsequently pled guilty to five counts of voyeurism. Defendant appealed, arguing that the district court erred in denying his motion to suppress because the warrant was not sufficiently particular and lack probable cause and because his statements to the officers violated his Fifth Amendment right against self-incrimination. The Supreme Court affirmed, holding (1) the warrant was sufficiently particular and supported by probable cause; and (2) Defendant was not in custody at the time he made the statements to the law enforcement officers so the officers’ failure to read him his Miranda rights did not violate the Fifth Amendment. View "State v. Fuller" on Justia Law