Justia Government & Administrative Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court granting Robyn Young's motion to dismiss this action brought by Granite School District regarding settlement proceeds Young had received for industrial injuries, holding that the Labor Commission had exclusive jurisdiction over the factual questions at the heart of this reimbursement dispute.Young, a special education teacher, sought workers' compensation for injuries she received at the hands of her students. An administrative law judge awarded Young benefits, finding that Young was permanently and totally disabled and that Young did not have to reimburse Granite with funds she received from a legal settlement she had obtained against medical debt collectors for violations of the Fair Debt Collection Practices Act. Granite then initiated suit for reimbursement from Young under the Utah Workers' Compensation Act. The district court granted Young's motion to dismiss. The Supreme Court affirmed, holding that the district court did not err when it dismissed Granite's complaint because the Workers' Compensation Act assigned the Commission exclusive jurisdiction over this dispute. View "Granite School District v. Young" on Justia Law

The Supreme Court affirmed the order of the Public Service Commission (PSC) denying in part and granting in part motions for reconsideration of an order it issued setting forth the inputs it would use to calculate the export credit rate (ECR), holding that this Court lacked jurisdiction as to certain issues and, as to the two remaining issues, the PSC did not exceed the bounds of its authority.The export credit rate system at issue in this case was created to eventually replace the "net metering" program for customers who generated electricity. The PSC engaged in a lengthy public process to decide what factors to consider in calculating the ECR. After the PSC issued an order setting forth the inputs to use for the ECR Appellants filed motions for reconsideration. The PSC granted in part the motions, agreeing to reconsider some of the ECR calculation's components. The Supreme Court dismissed the petition as to issues for which the Court lacked jurisdiction and otherwise denied the motion, holding that the PSC did not exceed the bounds of its authority. View "Vote Solar v. Public Service Comm'n" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court concluding that Pleasant Grover (City) had the power to enact a three-tiered "transportation utility fee" (TUF) but reversed the court's ruling that the TUF was actually a tax, holding that remand was required.The subject TUF charged local property owners a monthly fee corresponding to the "intensity" with which they used City roads, as determined by a study of user demand on the City's roadways, and the generated funds were to be used to repair and maintain city roadways only. At issue was whether the City had the authority to enact the TUF and whether the City properly characterized the TUF as a fee or if it was in fact a tax requiring the City to follow specific enactment procedures. The district court held that the TUF was actually a tax based on its purpose. The Supreme Court reversed in part, holding (1) the City acted within its discretion in enacting the TUF; but (2) the purpose of the TUF was characteristic of a fee because it was a specific charge for a specific purpose. View "Larson v. Pleasant Grove City" on Justia Law

The Supreme Court reversed the determination of the court of appeals that Claimant's long drive in a commercial truck was not an unusual or extraordinary activity in comparison to the ordinary activities people perform in their nonworking, everyday lives and vacated the conclusion that there was substantial evidence to support the ALJ's finding that Claimant's "super obesity" was a preexisting condition, holding that Claimant was entitled to benefits.At the end of a three-day drive from Utah to California, Claimant was diagnosed with a blood clot in his left leg, which caused blood clots in his lungs. Claimant could not return to work and sought workers' compensation. Employer disputed the claim, arguing that his injuries were caused by his "super obesity" and that super obesity should be considered a preexisting condition under the circumstances. The ALJ granted benefits, concluding that Claimant had satisfied the Allen v. Industrial Comm'n, 729. P.2d 15 (Utah 1986), test for legal causation. The Labor Commission Appeals Board reversed, concluding that Claimant's work activities were not unusual or extraordinary under Allen. The Supreme Court reversed, holding (1) Claimant's drive to California was an unusual activity; and (2) therefore, Claimant showed legal causation. View "JBS Carriers v. Hickey" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals upholding the decision of the Utah Procurement Policy Board to dismiss ICS Corrections, Inc.'s appeal of the decision of the Utah Division of Purchasing and General Services to award a multi-year telecommunications contract to another bidder, holding that the Board neither clearly erred nor acted arbitrarily or capriciously in dismissing ICS's appeal on the basis that it failed to attach a copy of the protest decision to its notice of appeal within the appeal deadline.In declining to disturb the Board's decision, the court of appeals held that the statutory requirements outlined in the pertinent provision of the Utah Procurement Code compelled strict compliance with their terms. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the Legislature has unequivocally required the Board to dismiss an appeal where the appellant has failed to attach a copy of the protest decision to its notice of appeal within the appeal deadline; and (2) therefore, ICS's appeal must be dismissed. View "ICS Corrections, Inc. v. Procurement Policy Board" on Justia Law

The Supreme Court reversed the decision of the Labor Commission Appeals Board dismissing Appellant's interlocutory objection to the appointment of the medical panel assigned to resolve this dispute, holding that the actual bias standard applied by the Board to resolve Appellant's conflict of interest objection did not comport with the statutory requirements.Appellant sought workers' compensation benefits after he injured his back in a work-related accident. The administrative law judge assigned to the case appointed a medical panel to resolve the dispute and appointed Dr. Jeremy Biggs, an occupational medicine physician, to serve as the panel chair. Appellant moved for interlocutory review, arguing that Dr. Biggs should be disqualified because he had a conflict of interest. The Board rejected Appellant's objections and concluded that the accident had not caused permanent injury. The Supreme Court reversed, holding (1) where a medical panelist's impartiality could be reasonably questioned the requirement of an impartial medical evaluation has not been met; and (2) remand was required on this basis. View "Gamez v. Utah Labor Commission" on Justia Law

The Supreme Court reversed the decision of the court of appeals finding that Northern Monticello Alliance (NMA) had a due process right to participate in the hearing leading to the San Juan County Planning and Zoning Commission's decision not to revoke a wind farm's conditional use permit (CUP), holding that NMA did not possess such a right.NMA complained to the Planning Commission that the wind farm was not fulfilling the conditions of its CUP. After a hearing at which NMA was not allowed to participate, the Planning Commission voted not to revoke the CUP. The San Juan County Commission ultimately upheld the Planning Commission's decision not to revoke the CUP. The district court affirmed. The court of appeals reversed, concluding that NMA members had due process rights granted by the County Land Use, Development, and Management Act and the San Juan County Zoning Ordinance and the San Jan County Zoning Ordinance. The Supreme Court reversed, holding that NMA did not have a protectable due process interest in the enforcement of the CUP or in participation in the revocation hearing. View "Northern Monticello Alliance v. San Juan County" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing on summary disposition the denial of Appellant's appeal from the denial of unemployment benefits, holding that following the plain language of Utah Code 35A-4-403 in requiring a claimant who has obtained a work-search deferral to be nonetheless able and available to accept full-time employment does not produce an absurd result.Appellant sought unemployment benefits after he was temporarily laid off from his job. The Department of Workforce Services denied benefits because Appellant had indicated on his application that he was unavailable to accept full-time work because he would be returning to his former employer. The Department deferred the requirement that Appellant actively seek employment while receiving benefits but still required him to be able and available to accept full-time work under section 35A-4-403. The ALJ and the workforce appeals board denied Appellant's appeal. The court of appeals reversed, concluding that interpreting the statute to require a claimant who had obtained a work-search deferral to nonetheless be able and available to accept full-time employment worked an absurd result. The Supreme Court reversed, holding that the Department properly denied Appellant's claim for unemployment. View "Arnold v. Department of Workforce Services" on Justia Law

The Supreme Court reversed the district court's dismissal of this complaint brought by the Southern Utah Wilderness Alliance (SUWA) alleging that the San Juan County Commission violated SUWA's rights under Utah's Open and Public Meetings Act, Utah Code 52-4-101 to 52-4-305, holding that SUWA's complaint was sufficient to survive dismissal.The district court dismissed the complaint on the grounds that SUWA failed to allege that the participants in the disputed meetings had discussed a matter over which the Commission had jurisdiction or advisory power. The Supreme Court reversed, holding (1) SUWA had standing to bring a challenge under the Act; and (2) the district court erred in dismissing SUWA's claims because the pleadings in SUWA's complaint were sufficient even if this Court were to adopt a proposed interpretation of the Act proffered by the Commission. View "Southern Utah Wilderness v. San Juan County Commission" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing this complaint brought by the Southern Utah Wilderness Alliance (SUWA) alleging that the Kane and Garfield County Commissions violated Utah's Open and Public Meetings Act (the Act), Utah Code 52-4-101 to 52-4-305, holding that the district court erred.The dispute leading to this litigation was whether the Commissions violated the Act when they failed to provide public notice or allow attendance at certain Commission members had with the United States Secretary of the Interior. The district court dismissed SUWA's complaint for lack of standing and concluded that the Act did not apply to the meetings at issue. The Supreme Court reversed, holding (1) SUWA had standing to bring these claims; and (2) the court erred in concluding that the Act did not apply because, even under the district court's interpretation of the Act, the allegations in SUWA's complaint were sufficient to survive a motion to dismiss. View "Southern Utah Wilderness Alliance v. Kane County Commission" on Justia Law