Camco Construction, Inc. v. Utah Baseball Academy, Inc., 2010 UT 63

Summary

The Utah Supreme Court affirmed the denial of a motion to disqualify a trial judge who had been exposed to confidential arbitration materials. The court held that the motion was untimely under Utah Rule of Civil Procedure 63(b) because the moving parties knew or should have known of the grounds for disqualification more than twenty days before filing and had not shown good cause for the delay. The court therefore declined to reach the merits of the confidentiality and recusal arguments.

Holdings

1. Utah Rule of Civil Procedure 63 governs motions to disqualify a judge regardless of whether the motion invokes that rule or is presented under another legal theory; a party may not avoid Rule 63's deadline by labeling the motion differently.
2. API's motion to disqualify Judge Quinn was untimely under Utah Rule of Civil Procedure 63(b)(1)(B), and API failed to demonstrate good cause for its delay.
3. Because API's motion was untimely and unsupported by good cause, the court declined to reach the merits of whether exposure to confidential arbitration materials required Judge Quinn's recusal.

Questions Presented

1. Whether API's motion to disqualify Judge Quinn was timely under Utah Rule of Civil Procedure 63(b)(1)(B).
2. Whether the Supreme Court of Utah should reach the merits of API's argument that exposure to confidential arbitration materials required Judge Quinn's disqualification.

Disposition

affirmed