Justia Government & Administrative Law Opinion Summaries

In connection with the Utah Transit Authority's construction of a high-speed commuter rail line, the Utah Department of Transportation (UDOT) classified a certain railroad crossing as public. The Public Service Commission upheld the classification. Union Pacific Railroad sought review of the Commission's decision upholding UDOT's public classification. The Supreme Court affirmed, concluding that the Commission did not err in determining that UDOT correctly classified the crossing as public, as Union Pacific failed to present enough evidence to support its arguments that the crossing was formally vacated or abandoned or that the crossing was a new road that never became public. View "Union Pac. R.R. v. Utah Dep't of Transp." on Justia Law

Petitioner was traveling home from work in his personal vehicle when he sustained back injuries in a car accident. Petitioner applied for workers' compensation benefits, but his application was denied under the "going and coming rule," which deems injuries occurring during a work commute outside the course of employment and thus not compensable. Petitioner appealed, arguing that in light of the benefits his employer received through various work-related uses of his vehicle, he was "in the course of employment" during the accident. The labor commission and court of appeals rejected Petitioner's claim that he qualified under the "instrumentality" exception of the going and coming rule. The Supreme Court affirmed, holding that Petitioner fell within the rule and not the exception. View "Jex v. Utah Labor Comm'n" on Justia Law

Wade Marinoni was employed as a first-response emergency medical technician (EMT) for Carbon County. After an incident involving an immediate transport of a patient having a heart attack, Marinoni was fired for failing to immediately respond to the transport request. Marinoni applied for and was awarded unemployment benefits. The ALJ affirmed, finding that Marinoni had acted in good faith according to his understanding of his employer's protocol. The Workforce Board of Appeals affirmed, concluding that Carbon County did not meet its burden to demonstrate just cause for termination. The Supreme Court affirmed the court of appeals' ultimate determination upholding the award of unemployment benefits, holding (1) the court of appeals erred in declining to consider in its legal analysis the uncontested fact that Marinoni knew the patient was having a heart attack; but (2) the Board's legal conclusions regarding culpability were within the scope of the deference granted to the Board's decision. View "Carbon County v. Workforce Appeals Bd." on Justia Law

Petitioner was working as a park ranger for Utah State Parks and Recreation when he suffered pain in his lower back after losing then regaining his balance on a boat dock while preparing to go on boating patrol. The Utah Labor Commission denied Petitioner's claim for benefits, concluding that the accident had aggravated a preexisting lower back condition and but that the unexpected wave that caused Petitioner to slightly lose his balance was not the legal cause of Petitioner's injury. The court of appeals affirmed. The Supreme Court upheld the court of appeals' ultimate decision to deny Petitioner compensation benefits; holding (1) the court of appeals erred in applying an abuse of discretion standard of review to the Commission's decision; but (2) even under a nondeferential standard of review, Petitioner failed to establish that his boat accident, rather than his preexisting back condition, was the legal cause of his injury. View "Murray v. Utah Labor Comm'n" on Justia Law

While employed with Employer, Employee agreed to arbitrate any disputes arising from his employment. Employee's employment was later terminated. Employee filed a charge of discrimination with the Utah Anti-Discrimination and Labor Division of the Utah Labor Commission (UALD), alleging that Employer discriminated against him, retaliated against him, and harassed him. The UALD dismissed Employee's discrimination claims. Employee appealed to the Utah Labor Commission. The district court subsequently granted Employer's motion to compel arbitration and ordered Employee to submit to arbitration. The Supreme Court vacated the order compelling arbitration, holding that the district court erred in compelling arbitration because the plain language of the arbitration clause in Employee's employment contract allowed him to pursue administrative remedies prior to submitting to arbitration. View "Zions Mgmt. Servs. v. Record" on Justia Law

In 1990, Chin Lee established a defined-benefit plan, which he converted in 1996 into a profit-sharing plan, both of which were qualified plans. Chin's sole proprietorship contributed funds to the Plan from 1990 to 1995. These funds were invested entirely in U.S. government obligations, the interest on which was tax-exempt. In their 2005 and 2006 tax filings, Chin and Yvonne Lee reported Plan distributions and claimed deductions for federal obligation interest that the Plan earned in those and in earlier years. The Utah State Tax Commission disallowed these deductions, concluding that the Lees' distributions from the Plan were not exempt from state taxation even though the Plan assets were invested solely in U.S. government obligations. The Supreme Court affirmed, holding that no portion of the Plan distributions was tax-exempt, as (1) the distributions from the Plan qualified for a tax exemption only if the Plan acted as a conduit, allowing the funds to retain their tax-exempt character after distribution; and (2) the Lees' qualified profit-sharing plan was a non-conduit entity, and thus, the funds did not retain their character as interest on U.S. obligations upon distribution to the Lees. Therefore, the distributions were fully taxable by Utah. View "Lee v. Utah State Tax Comm'n " on Justia Law

In 2003, the City of Salt Lake asked voters to approve Proposition No. 5, which proposed the issuance of bonds to finance construction of a regional sports, recreation, and education complex. Voters approved the bonds. In 2011, the City authorized issuance of the bonds with Resolution No. 5 and then filed a petition to validate the Proposition No. 5 bonds in district court. Appellants, the Jordan River Restoration Network and several citizens, appeared pro se to oppose the City's petition, challenging the bonds' validity on several statutory and constitutional grounds. The district court denied Appellants' claim and granted the City's validation petition. The Supreme Court affirmed the City's validation petition, holding (1) the district court conducted the validation proceedings in compliance with due process and the Validation Act; and (2) the district court correctly applied the Local Government Bonding Act. View "Salt Lake City Corp. v. Jordan River Restoration Network" on Justia Law

This case required the Supreme Court to determine when a well "started" under Utah Code 59-5-102. Although that statute imposes a severance tax on oil or gas produced from a well, section 59-5-102(5)(c) permits an exemption for "the first six months of production for development wells started after January 1, 1990." Summit Operating, LLC argued that a well starts when it begins commercial production. Under this interpretation, Summit asserted that it was entitled to a six-month tax exemption for its well, which started commercial production in 2008. The Utah State Tax Commission asserted that a well starts on the date that drilling begins, and thus, Summit was not entitled to the tax exemption because drilling for Summit's well began in 1983. The Supreme Court affirmed the Commission's order granting summary judgment to the Auditing Division of the Commission, holding that under the Tax Exemption Statute, a well "starts" when drilling begins. View "Summit Operating v. State Tax Comm'n" on Justia Law

This appeal resulted from an action in eminent domain in which the Utah Department of Transportation sought to condemn an access point easement on property owned by FPA West Point. FPA's codefendant and lessee, Kmart Corporation, also claimed an interest in the access. Because of the different interests claimed by FPA and Kmart, FPA filed a motion asking the court to order separate just compensation determinations. The district court granted the motion. The Supreme Court held (1) the district court was correct in determining that the values of respective interests in a parcel of condemned property must be individually assessed; (2) the value of respective interests may be individually assessed in either separate or consolidated proceedings; (3) accordingly, the district court has discretion to order separate proceedings in an action involving multiple interest holders in a condemned parcel of property; and (4) because it was unclear whether the district court intended that FPA's and Kmart's interests be assessed through separate or through consolidated proceedings, the case was remanded with instructions to determine whether to order separate or consolidated proceedings in this matter. View "Utah Dep't of Transp. v. FPA West Point, LLC" on Justia Law

Sunnyside Coal Company (Sunnyside), the Employers' Reinsurance Fund (ERF), and the Workers' Compensation Fund (WCF) (collectively, Petitioners) challenged the Labor Commission's award of permanent total disability benefits to Claimant. Petitioners argued that the award was barred under the relevant statute of limitation, which prevented the labor commission from acquiring jurisdiction and making the award. The Supreme Court affirmed the commission's award of permanent total disability benefits but remanded for a determination of the correct amount of compensation, holding (1) the commission correctly determined it had original jurisdiction over the claim and also correctly exercised its continuing jurisdiction in awarding compensation; (2) because of the long delay in bringing the claim, however, Claimant's recovery was equitably limited; and (3) ERF was obligated to pay only prospective benefits from the date of filing, and Sunnyside and WCF were not liable for any permanent total disability benefits. View "Employers' Reinsurance Fund v. Henningson" on Justia Law