Fundamentalist Church of Jesus Christ of Latter-Day Saints v. Lindberg

Summary

The Utah Supreme Court reviewed an extraordinary-writ petition challenging the district court’s modification and administration of the United Effort Plan Trust. The court held that claims concerning the trust’s modification and most administration claims were barred by laches because of the petitioner’s delay and resulting prejudice to other parties. The court held that the remaining administration claim was not ripe for adjudication.

Holdings

1. The FLDS Association's claims challenging the district court's modification of the UEP Trust were barred by laches because the Association delayed nearly three years and that delay prejudiced parties who relied on the unchallenged modification order.
2. The FLDS Association's Trust-administration claims arising from events occurring during or before the Trust's modification were also barred by laches because the Association lacked diligence and its delay prejudiced other parties.
3. The claim that the district court might use religion to determine future distributions of Trust property was not ripe because the FLDS Association alleged no actual discriminatory distribution and no imminent clash of legal rights.

Questions Presented

1. Whether the FLDS Association's challenge to the district court's 2006 modification of the UEP Trust was barred by laches.
2. Whether the FLDS Association's claims concerning the district court's subsequent administration of the Trust were barred by laches.
3. Whether the claim that the district court might use religion to determine Trust-property distributions was ripe for adjudication.
4. Whether extraordinary relief under Utah Rule of Civil Procedure 65B should be granted.

Disposition

dismissed