Davis County v. Purdue Pharma, L.P.

Summary

The Utah Supreme Court affirmed an order transferring Davis County’s opioid-litigation action from the Second District to the Third District for discovery and pretrial proceedings. The court held that Utah district courts possess inherent authority to order such multidistrict pretrial transfers, that Utah Rule of Civil Procedure 42 and Utah Code section 78B-3-309 do not independently authorize the transfer, and that the lower court did not abuse its discretion.

Holdings

1. Utah district courts possess inherent authority to transfer an action from one judicial district to another for discovery and pretrial proceedings in the interests of justice and judicial economy.
2. Utah Rule of Civil Procedure 42 does not authorize a multi-district transfer from one judicial district to another.
3. Utah Code section 78B-3-309 does not authorize a multi-district transfer for discovery and pretrial proceedings and does not preempt the district court's inherent authority to order such a transfer.
4. The Second District acted within the bounds of its discretion by transferring the Davis County action to the Third District for discovery and pretrial proceedings.

Questions Presented

1. Whether a Utah district court has authority to transfer an action from one judicial district to another for discovery and pretrial proceedings.
2. Whether Utah Rule of Civil Procedure 42 authorizes a multi-district transfer for pretrial purposes.
3. Whether Utah Code section 78B-3-309 authorizes or preempts inherent judicial authority to transfer a case for pretrial purposes.
4. Whether the Second District abused its discretion by transferring the Davis County action to the Third District for discovery and pretrial proceedings.

Disposition

affirmed