mere technical violation (Utah) · Go Syfert
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mere technical violation in Utah

5 Utah opinions name it 2 courts 1978–2026 3 in the last five years

The cases below were cited by Utah courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (3)

CaseFollowedCited
Kelly v. Timber Lakes Propertygreen
utahctapp · 2022 · cited in 2 Utah opinions naming this issue, 2022–2022
2 sentences

2022See Timm v. Dewsnup, 2003 UT 47, ¶ 37 , 86 P.3d 699 (“Whatever irregularities [the debtor] may allege in the technicalities of the notice requirement, they are immaterial if she does not demonstrate that she was unable to protect her interests, or if there were a resulting effect of chilling the bidding and causing an inadequacy of price.”) (quotation simplified). 20191079-CA 27 2022 UT App 23 Kelly v. Timber Lakes ¶52 Kelly contends that the trustee’s failure to wait the full three-month period is not a mere technical violation.

2022See Timm v. Dewsnup, 2003 UT 47, ¶ 37 , 86 P.3d 699 (“Whatever irregularities [the debtor] may allege in the technicalities of the notice requirement, they are immaterial if she does not demonstrate that she was unable to protect her interests, or if there were a resulting effect of chilling the bidding and causing an inadequacy of price.”) (quotation simplified). 20191079-CA 27 2022 UT App 23 Kelly v. Timber Lakes ¶52 Kelly contends that the trustee’s failure to wait the full three-month period is not a mere technical violation.

22
Timm v. Dewsnupgreen
utah · 2003 · cited in 2 Utah opinions naming this issue, 2022–2022
2 sentences

2022See Timm v. Dewsnup, 2003 UT 47, ¶ 37 , 86 P.3d 699 (“Whatever irregularities [the debtor] may allege in the technicalities of the notice requirement, they are immaterial if she does not demonstrate that she was unable to protect her interests, or if there were a resulting effect of chilling the bidding and causing an inadequacy of price.”) (quotation simplified). 20191079-CA 27 2022 UT App 23 Kelly v. Timber Lakes ¶52 Kelly contends that the trustee’s failure to wait the full three-month period is not a mere technical violation.

2022See Timm v. Dewsnup, 2003 UT 47, ¶ 37 , 86 P.3d 699 (“Whatever irregularities [the debtor] may allege in the technicalities of the notice requirement, they are immaterial if she does not demonstrate that she was unable to protect her interests, or if there were a resulting effect of chilling the bidding and causing an inadequacy of price.”) (quotation simplified). 20191079-CA 27 2022 UT App 23 Kelly v. Timber Lakes ¶52 Kelly contends that the trustee’s failure to wait the full three-month period is not a mere technical violation.

22
Bank of America v. Adamsongreen
utah · 2017 · cited in 2 Utah opinions naming this issue, 2022–2022
2 sentences

2022Indeed, he asserts that “the assumption that the trustor would use this full time was the basis for the Utah Supreme Court holding that in most cases a trustee’s deed cannot be voided for ‘technical defects’ in the foreclosure process after the foreclosure sale.” In support of this contention, he points to the Court’s statement that the requirement “that a trustor assert her rights before the trustee’s sale . . . is consistent with the statutory right to cure the default, which also must be exercised during the three-month grace period before a trustee’s sale is held.” Adamson, 2017 UT 2, ¶ 16

2022Indeed, he asserts that “the assumption that the trustor would use this full time was the basis for the Utah Supreme Court holding that in most cases a trustee’s deed cannot be voided for ‘technical defects’ in the foreclosure process after the foreclosure sale.” In support of this contention, he points to the Court’s statement that the requirement “that a trustor assert her rights before the trustee’s sale . . . is consistent with the statutory right to cure the default, which also must be exercised during the three-month grace period before a trustee’s sale is held.” Adamson, 2017 UT 2, ¶ 16

22

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Utah. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
State v. Collins green
utah · 2014
2 sentences

2026A. Notice ¶23 “A mere technical violation of a rule is insufficient to justify relief without a showing of prejudice.” State v. Collins, 2014 UT 61, ¶ 42 , 342 P.3d 789 (cleaned up); see Utah R.

2026A. Notice ¶23 “A mere technical violation of a rule is insufficient to justify relief without a showing of prejudice.” State v. Collins, 2014 UT 61, ¶ 42 , 342 P.3d 789 (cleaned up); see Utah R.

12026–2026
JENNINGS INVESTMENT, LC v. Dixie Riding Club, Inc. green
utahctapp · 2009
2 sentences

2012The district court, however, has discretion to decide how to handle noncompliance with rule 7 and may require strict compliance with the rule or may “regard the failure to comply with the rule as a mere technical violation and consider the motion on its merits.” Jennings Inv., LC v. Dixie Riding Club, Inc., 2009 UT App 119, ¶ 24 , 208 P.3d 1077 .

2012The district court, however, has discretion to decide how to handle noncompliance with rule 7 and may require strict compliance with the rule or may “regard the failure to comply with the rule as a mere technical violation and consider the motion on its merits.” Jennings Inv., LC v. Dixie Riding Club, Inc., 2009 UT App 119, ¶ 24 , 208 P.3d 1077 .

12012–2012
Commonwealth National Bank v. Kennedy Company green
utah · 1973
2 sentences

1978Commonwealth National Bank v. Kennedy Co., 29 Utah 2d 83 , 505 P.2d 298 ; 66 C.J.S.

1978Commonwealth National Bank v. Kennedy Co., 29 Utah 2d 83 , 505 P.2d 298 ; 66 C.J.S.

11978–1978
Donahue v. Warner Bros. Pictures Distributing Corp. green
utah · 1954
2 sentences

1978NOTES [1] Section 76-4-8, repealed in 1973, provided in contrast to the present language: "Any person who uses for advertising purposes or for purposes of trade, or upon any postal card, the name, portrait or picture of any person . ." [1] U.C.A. 1953, Sec. 76-9-405, enacted by Laws of Utah 1973, Ch. 196. [2] 2 Utah 2d 256 , 272 P.2d 177 (1954). [1] Commonwealth National Bank v. Kennedy Co., 29 Utah 2d 83 , 505 P.2d 298 ; 66 C.J.S.

1978NOTES [1] Section 76-4-8, repealed in 1973, provided in contrast to the present language: "Any person who uses for advertising purposes or for purposes of trade, or upon any postal card, the name, portrait or picture of any person . ." [1] U.C.A. 1953, Sec. 76-9-405, enacted by Laws of Utah 1973, Ch. 196. [2] 2 Utah 2d 256 , 272 P.2d 177 (1954). [1] Commonwealth National Bank v. Kennedy Co., 29 Utah 2d 83 , 505 P.2d 298 ; 66 C.J.S.

11978–1978

Where else courts name it

CA 53 (1892–2026) IL 45 (1914–2026) NY 27 (1878–2023) PA 22 (1914–2023) MO 14 (1952–2024) IA 10 (1885–2021) NC 8 (1974–2009) OH 7 (1983–2025) LA 7 (1962–2026) FL 7 (1960–2001) VT 6 (1984–2017) SC 6 (1940–1998) UT 5 (1978–2026) TX 5 (1952–2013) KS 4 (1897–2016) MS 4 (1990–2024) MN 4 (1991–1997) WV 4 (1900–2008) OR 4 (1978–1995) WA 3 (2001–2023) VA 3 (1987–2022) MT 3 (1922–1977) GA 3 (1918–1985) MI 3 (1991–2024) OK 3 (1929–1997) WI 3 (2002–2011) NJ 3 (1978–2009) AZ 2 (1927–1969) ID 2 (1992–2011) RI 2 (1959–2004) AL 2 (1930–1981) CO 2 (1971–1980) NM 2 (2012–2018) HI 2 (2013–2017) DC 2 (1943–1988)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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