Summary of Significant Utah Supreme Court Cases 2008-2009
| Jurisdiction | Utah,United States |
| Citation | Vol. 22 No. 5 Pg. 20 |
| Pages | 20 |
| Publication year | 2009 |
Vol. 22, No. 5, 20. Summary of Significant Utah Supreme Court Cases 2008-2009
Vol. 22, No.5
Sep/Oct 2009
State v. Moreno, 2009 UT 15, 203 P.3d 1000
Area of law: Juvenile, Fourth Amendment
Mr. Moreno's minor daughter was adjudicated delinquent for drug-related offenses. As part of her adjudication, the juvenile court ordered Mr. Moreno to submit to drug testing based on various findings and an allegation that Mr. Moreno and his girlfriend were "cooking meth in the hills." Mr. Moreno appealed the juvenile court's contempt charge against him for failure to submit to the court-ordered drug testing.
The court held that although juvenile courts are granted broad authority to impose orders on parents and hold them in contempt for failure to comply, this broad authority is limited to mandates that are reasonable. The court held that a reasonable condition must further the goals of the Act in that the sole motivation must be reforming the minor's behavior and there must be a logical connection between the alleged actions of the parent, the delinquent behavior of the minor, and the court-ordered condition. In addition, a condition cannot be reasonable if it violates constitutional rights. The court held that the standard for determining whether an administrative search is reasonable requires a balancing of the government's interest in operating its institutions and the individual's privacy interest. Key to this inquiry is an examination of whether the parent has a reduced expectation of privacy when their child is adjudicated delinquent. The court held that because a parent of a delinquent child did not have a reduced expectation of privacy, the government interest did not outweigh the privacy interest and probable cause was required for the search of Mr. Moreno. Because there was no probable cause for the search, the juvenile court's decision was reversed. Justices Durrant and Wilkins dissented. They would have held that whether Mr. Moreno's expectation of privacy was reduced was irrelevant to the assessment of reasonableness.
Helf v. Chevron, 2009 UT 11, 203 P.3d 962
Area of law: Personal Injury, Workers' Compensation
Jenna Helf sued Chevron U.S.A., Inc., for injuries she sustained while working at the Salt Lake City Refinery. On the day Ms. Helf was injured, Chevron initiated a chemical reaction in an open-air pit that created a toxic cloud and set off chemical alarms at the Refinery. Several workers were sent home due to illness. When Ms. Helf arrived for her shift, her supervisor had her initiate the same reaction without informing her of the earlier result and without informing her that she needed special respiratory equipment. When Ms. Helf initiated the reaction, toxic gasses were again released, which caused Ms. Helf to vomit and lose consciousness. As a result of her exposure to the toxic gases, Ms. Helf now suffers from a permanent seizure disorder. Ms. Helf was awarded compensation under the Workers' Compensation Act. She also brought suit against Chevron, alleging willful misconduct, intentional nonfeasance, negligent infliction of emotional distress, and intentional infliction of emotional distress. Chevron filed a 12(b)(6) motion, arguing that the exclusive remedy provision of the Workers' Compensation Act barred Ms. Helf's claim. The district court granted Chevron's motion and Ms. Helf appealed.
Although compensation under the Workers' Compensation Act is normally the exclusive remedy for a worker injured on the job, if the injury is intentional, the worker may bring a tort action against the employer. The level of intent necessary to trigger the intentional injury exception was the focus of this case. The court affirmed the intent to injure standard articulated in Lantz v. national Semiconductor Corp., 775 P.2d 937 (Utah Ct. App. 1989), but clarified how it is to be used to distinguish between intentional and accidental injuries. The court held...
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