Summary
The Utah Supreme Court held that Kelly Laws lacked traditional standing to challenge Willie Grayeyes's election because Laws alleged no injury particularized to him rather than shared by San Juan County voters generally. The court declined to reach Laws's statutory-standing argument because it was inadequately briefed and vacated the district court's merits decision. The court affirmed the denial of Grayeyes's request for attorney fees, concluding that the district court did not improperly limit its equitable authority and that Grayeyes was not entitled to fees under the private attorney general doctrine.
Topics
Practice areas
Questions Presented
- Whether Laws had traditional standing to challenge Grayeyes's election when his alleged injury was shared by other registered voters and the public.
- Whether statutory authorization allowing a registered voter to contest an election independently conferred standing despite the absence of traditional standing.
- Whether Utah Code section 78B-5-825 unconstitutionally limited the courts' authority to award attorney fees under general equitable principles.
- Whether Grayeyes was entitled to attorney fees under the private attorney general doctrine.
Holdings
- A plaintiff challenging an election must allege a sufficiently particularized injury that gives the plaintiff a personal stake in the dispute. A registered voter's generalized interest in having only eligible candidates elected is shared with other voters and the public and is insufficient.
- The court did not decide whether the Legislature could confer standing by statute on a plaintiff who lacks traditional standing because Laws inadequately briefed the constitutional and statutory issues.
- Utah Code section 78B-5-825 does not unconstitutionally limit courts' authority to award attorney fees under general equitable principles, and its good-faith standard encompasses conduct that is vexatious, wanton, or oppressive.
- Even assuming the continuing vitality of the private attorney general doctrine, Grayeyes was not entitled to fees because his defense of the election challenge did not vindicate an important public policy or thwart unlawful government conduct.
Key quotations
“First, the party must assert that it has been or will be adversely affected by the [challenged] actions. Second, it must allege a causal relationship between the injury to the party, the [challenged] actions, and the relief requested. And third, it must request relief that is substantially likely to redress the injury claimed.” (¶ 27)
“Laws has not alleged a sufficiently particularized injury to support traditional standing.” (¶ 64)
“This statute does not impose an unconstitutional limitation on courts' authority to award fees according to general equitable principles.” (¶ 65)
Factual background
Willie Grayeyes declared his candidacy for San Juan County Commissioner and supplied coordinates and satellite images for a residence on Navajo Mountain because homes there often lacked street addresses. Kelly Laws knew of an earlier residency challenge but did not file his own challenge until after Grayeyes defeated him in the election. At trial, the evidence concerned Grayeyes's substantial ties to San Juan County, including his cultural, political, employment, and historical connections there, as well as his occasional presence and property in Arizona.
Procedural history
Grayeyes won the 2018 election for San Juan County Commissioner. Laws filed a statutory election contest challenging Grayeyes's eligibility based on residency. After a bench trial, the Seventh District Court concluded that Grayeyes was a San Juan County resident, rejected Laws's challenge, and denied Grayeyes's request for attorney fees. The Utah Supreme Court held that Laws lacked traditional standing, dismissed the election challenge for lack of jurisdiction, vacated the district court's merits ruling, and affirmed the denial of attorney fees.
Remand instructions
No remand instructions were stated. The election-contest claim was dismissed for lack of jurisdiction, the district court's merits decision was vacated, and the denial of attorney fees was affirmed.