State ex rel. School & Institutional Trust Land Administration v. Mathis

Summary

The Utah Supreme Court held that Utah's constitutional role as trustee of school and institutional trust lands does not exempt the State from the seven-year statute of limitations in Utah Code section 78B-2-201. The court concluded that the State, rather than innocent purchasers, must bear the loss resulting from its own alleged mismanagement in conveying trust land for less than full value. The court affirmed summary judgment for the Mathises and disavowed prior suggestions that such conveyances are automatically null and void.

Holdings

1. Utah Code section 78B-2-201 may constitutionally be applied to bar the State's action concerning the Mathis Property.
2. The Utah Constitution does not give the State a constitutional right to void a conveyance of school trust lands solely because the conveyance was made for less than full value.
3. A conveyance of school trust lands made for less than full value is effective; the State must reimburse the trust for the resulting loss rather than shifting the loss to an innocent purchaser.
4. Van Wagoner does not establish a blanket constitutional rule that statutes of limitations may never apply to school trust lands; at most, it is limited to the adverse-possession context.

Questions Presented

1. Whether Utah Code section 78B-2-201's seven-year statute of limitations constitutionally applies to the State's action concerning school and institutional trust lands.
2. Whether the Utah Constitution gives the State a right to invalidate or recover damages for its own conveyance of school trust land made for less than full value.
3. Whether Van Wagoner v. Whitmore and Consolidation Coal Co. v. Utah Division of State Lands & Forestry required a different result.

Disposition

affirmed