Summary
The Utah Supreme Court held that the Utah Constitution guarantees a jury trial in a small-claims trial de novo in district court. It concluded that Utah Code section 78B-1-104(4) was unconstitutional as applied to such proceedings and that Simler properly asserted and preserved her jury-trial right. The court declined to reach Simler’s constitutional challenges to the exclusion of pretrial discovery because those arguments were not preserved.
Topics
Practice areas
Questions Presented
- Whether the Utah Constitution guarantees a right to a jury trial in a small claims case proceeding to a trial de novo in district court.
- Whether Simler properly asserted and preserved her right to a jury trial.
- Whether Simler preserved her constitutional challenges to the preclusion of pretrial discovery in the district court trial de novo proceeding.
Holdings
- Article I, section 10 of the Utah Constitution guarantees the right to a jury trial in a small claims case at the trial de novo stage in district court; Utah Code section 78B-1-104(4) is unconstitutional as applied to such proceedings.
- Simler properly asserted and preserved her right to a jury trial by filing and serving a written jury demand, paying the required statutory fee, and raising the constitutional issue in opposition to the motion to strike.
- Simler did not adequately preserve her constitutional challenges to the preclusion of pretrial discovery, so the court declined to reach their merits.
Key quotations
“We conclude that the Utah Constitution guarantees the right to a jury trial in small claims cases in a trial de novo in district court, and that Ms. Simler properly asserted that right.” (¶ 2)
“Therefore, Utah Code section 78B-1-104(4) is an unconstitutional deprivation of article I, section 10’s guarantee of the right to jury trial in appeals from small claims judgments to district courts.” (¶ 17)
“Because Ms. Simler properly asserted and preserved the right to a jury trial, that portion of the district court’s order striking Ms. Simler’s motion and demand for jury trial is hereby reversed.” (¶ 23)
Factual background
Chilel alleged that she suffered physical injuries in an automobile collision with Simler and sought $10,000 in general and special damages in small claims court. At trial, evidence indicated that Chilel had been involved in multiple other automobile accidents and claimed similar injuries, while the medical documentation presented covered only a limited period. The small claims court entered a judgment of no cause of action, after which Chilel sought a trial de novo in district court and Simler filed an answer, jury demand, and limited discovery requests.
Procedural history
Chilel sued Simler in small claims court for injuries allegedly arising from an automobile collision and received a judgment of no cause of action. Chilel appealed for a trial de novo in district court. The district court struck Simler's answer, jury demand, and discovery requests as procedurally improper. The Utah Supreme Court granted Simler's petition for permission to appeal.
Remand instructions
The portion of the district court's order striking Simler's motion and demand for a jury trial was reversed; the portion striking the discovery requests was affirmed. The opinion does not state additional specific remand instructions.