State v Lambdin

Lambdin sought review the Utah court of Appeals decision affirming his murder conviction and thereby rejecting his jury instruction argument about “extreme emotional distress”. The Court, 3-2, affirmed. The majority held that it is proper for courts to construe statutes even when a phrase like “extreme emotional distress” has a common meaning, the Court’s definition of the phrase in the Bishop precedent (no mental illness; exposure to extremely unusual and overwhelming stress; and the average person would have an extreme emotional reaction resulting in loss of self-control and the person’s reason would be overborne by intense feelings like anger) has been used in several other cases and the definition in Bishop tracks the plain meaning of the phrase namely experiencing severe pain or suffering  accompanied by strong feelings like anger usually directed towards a specific person and accompanied by behavioral changes like loss of self- control. The majority held that loss of self-control must be proven as part of the special mitigation of extreme emotional distress as that is what the Bishop definition requires and the requirement serves the purpose of the defense to distinguish situations when a reasonable person’s capacity to action reasonably and rationally is overborn by the powerful emotional response from situations where the emotions provide the motivation for the actions but which do not render a reasonable person incapable of self-control. It rejected the State’s argument that killing itself must be reasonable as the statute only requires the distress be a reasonable reaction contemporaneous to the stress. The majority held the jury instructions given here, while possibly ambiguous in one instruction on what needs to be proven as reasonable, as a whole they adequately informed the jury that Lambdin need to prove the loss of self-control was reasonable, not the killing itself, noted that eh defense closing argument made it clear loss of self-control was the issue not the killing, and advised district courts in future cases to make clear that loss of self-control advised district courts to explicitly tell the jury that defendant must prove loss of self-control was reasonable not that the killing was reasonable. Chief Justice Durrant, joined by Himonas, argued the jury instructions were ambiguous about whether the “reaction” in the instruction which must be proven reasonable was the loss of self-control or the killing, other instructions did not clarify the ambiguity, the state offered an incorrect statement of the burden during its closing argument and the conviction must therefore be reversed.

Alpine Homes, Inc. v City of West Jordan

Alpine and other developers sued for refund of impact fees on constitutional and equitable grounds. City moved to dismiss the claims. The district court denied the motion then certified the issues for interlocutory appeal. The Court reversed. As to the constitutional claims, the Court held that Alpine and the other plaintiffs had statutory standing to challenge the basement of the fees, inadequately briefed their state constitutional argument and the federal claim failed as claims City spent the fees too late or on unauthorized items had no impact whatever on whether the assessment had an essential nexus and a rough proportionality between the fee and the public benefit. As to the equitable claim, the Court held Alpine and the other plaintiffs lacked standing as they had no contractual right to refund from purchasers of developed property and there is no right to recoup impact fees from purchasers of lots or finished homes, spending the fees in a timely manner for proper purposes is generalized grievance of City’s residents and Alpine can petition the legislature to create a statutory remedy.

Christensen v Juab School District

District appealed summary judgment to Christensen in his claim for reimbursement of attorney fees and costs under Utah Code 52-6-201 based on his acquittal on sex abuse charges. The Court affirmed. It held that under Court precedent, 201’s “under color of employee’s authority” provision applies when an information is field against a public official or employee (like public school teacher Christensen here) and it uses the status of official or employee as part of the charge as happened here, analysis is limited to the information not the actual underlying facts, all elements of 201 were met here and summary judgment was appropriate.