estoppel doctrine (Utah) · Go Syfert
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estoppel doctrine in Utah

23 Utah opinions name it 2 courts 1921–2025 4 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 (12)

CaseFollowedCited
Anderson v. Public Service Com'n of Utahgreen
utah · 1992 · cited in 2 Utah opinions naming this issue, 2022–2022
2 sentences

2022Anderson v. Public Service Comm’n, 839 P.2d 822, 828 (Utah 1992). ¶28 Cobblestone posits South Weber should be estopped from requiring Cobblestone to obtain a business license to operate the Property as an STR for two main reasons.

2022Anderson v. Public Service Comm’n, 839 P.2d 822, 828 (Utah 1992). ¶28 Cobblestone posits South Weber should be estopped from requiring Cobblestone to obtain a business license to operate the Property as an STR for two main reasons.

22
Morgan v. Board of State Landsgreen
utah · 1976 · cited in 2 Utah opinions naming this issue, 1983–1994
2 sentences

1994See Morgan, 549 P.2d at 697 n. 4 ("The doctrine of equitable estoppel does not operate in favor of one who has knowledge of the essential facts or who has convenient and available means of obtaining such knowledge.").

1983Moreover, the purpose of the doctrine of estoppel is “to rescue from loss a party who has, without fault, been deluded into a course of action by the wrong or neglect of another.” Rowley v. Marrerest Homeowners’ Association, Utah, 656 P.2d 414, 418 (1982) (quoting Morgan v. Board of State Lands, Utah, 549 P.2d 695, 697 (1976)) (emphasis added).

22
Lytle v. Household Manufacturing, Inc.green
scotus · 1990 · cited in 1 Utah opinions naming this issue, 2015–2015
2 sentences

2015See Lytle v. Household Mfg., Inc., 494 U.S. 545, 550 , 110 S.Ct. 1331 , 108 L.Ed.2d 504 (1990) ("When legal and equitable claims are joined in the same action, the right to jury trial on the legal claim, including all issues common to both claims, remains intact." (citation and internal quotation marks omitted).

2015See Lytle v. Household Mfg., Inc., 494 U.S. 545, 550 , 110 S.Ct. 1331 , 108 L.Ed.2d 504 (1990) ("When legal and equitable claims are joined in the same action, the right to jury trial on the legal claim, including all issues common to both claims, remains intact." (citation and internal quotation marks omitted).

11
Barbe v. Villeneuvegreen
fla · 1987 · cited in 1 Utah opinions naming this issue, 2015–2015
1 sentence

2015Mgmt. v. State, 799 A.2d 274 , 277 (R.I.2002) ("The doctrine of election of remedies is one that is grounded in equity and is designed to mitigate unfairness to both parties...." (emphasis added)); Barbe v. Villeneuve, 505 So.2d 1331, 1882 (Fla.1987) ("The election of remedies doctrine is an application of the doctrine of estoppel...."). +See also Am.

11
McLeod v. Retirement Boardgreen
utahctapp · 2011 · cited in 1 Utah opinions naming this issue, 2014–2014
2 sentences

2014See McLeod, 2011 UT App 190, ¶ 22 , 257 P.3d 1090 .

2014See McLeod, 2011 UT App 190, ¶ 22 , 257 P.3d 1090 .

11
Peterson v. Delta Air Lines, Inc.green
utahctapp · 2002 · cited in 1 Utah opinions naming this issue, 2014–2014
2 sentences

2014See Peterson v. Delta Air *939 Lines, Inc., 2002 UT App 56, ¶ 7 , 42 P.3d 1253 . 2 ANALYSIS 14 On appeal, the Myerses do not challenge the district court's determination that their December 1, 2009 notice of claim was valid.

2014See Peterson v. Delta Air *939 Lines, Inc., 2002 UT App 56, ¶ 7 , 42 P.3d 1253 . 2 ANALYSIS 14 On appeal, the Myerses do not challenge the district court's determination that their December 1, 2009 notice of claim was valid.

11
Premium Oil Co. v. Cedar Citygreen
utah · 1947 · cited in 1 Utah opinions naming this issue, 2006–2006
1 sentence

2006See Premium Oil, 187 P.2d at 204 .

11
Celebrity Club, Inc. v. Utah Liquor Control Commissiongreen
utah · 1979 · cited in 1 Utah opinions naming this issue, 2004–2004
2 sentences

2004In Celebrity Club, Inc. v. Utah Liquor Control Commission, 602 P.2d 689 (Utah 1979), for example, the Utah Supreme Court held that a letter written by the Liquor Control Commission indicating that a private club was in compliance with applicable zoning regulations was sufficiently specific so as to allow an estoppel claim to proceed.

2004See id. at 691 .

11
Federal Farm Mortg. Corporation v. Walkergreen
utah · 1949 · cited in 1 Utah opinions naming this issue, 2001–2001
2 sentences

2001Our reasons for so doing rested fundamentally upon the doctrine of estoppel." Federal Farm Mortgage Corp. v. Walker, 115 Utah 461 , 206 P.2d 146, 147 (1949). 10 .

2001Our reasons for so doing rested fundamentally upon the doctrine of estoppel." Federal Farm Mortgage Corp. v. Walker, 115 Utah 461 , 206 P.2d 146, 147 (1949). 10 .

11
Acton v. Delirangreen
utah · 1987 · cited in 1 Utah opinions naming this issue, 1991–1991
2 sentences

1991I think a safer course is steered by rather strict adherence to the requirement that adequate findings be made by the trial court, where required under Utah R.Civ.P. 52, with the only exception being where the failure to make findings is harmless, i.e., where “the facts in the record are ‘clear, uncontroverted, and capable of supporting only findings in favor of the judgment.’ ” Acton v. Deliran, 737 P.2d 996, 999 (Utah 1987) (emphasis added) (quoting Kinkella v. Baugh, 660 P.2d 233, 236 (Utah 1983)).

1991I think a safer course is steered by rather strict adherence to the requirement that adequate findings be made by the trial court, where required under Utah R.Civ.P. 52, with the only exception being where the failure to make findings is harmless, i.e., where "the facts in the record are `clear, uncontroverted, and capable of supporting only findings in favor of the judgment.'" Acton v. Deliran, 737 P.2d 996, 999 (Utah 1987) (emphasis added) (quoting Kinkella v. Baugh, 660 P.2d 233, 236 (Utah 1983)).

11
Kinkella v. Baughgreen
utah · 1983 · cited in 1 Utah opinions naming this issue, 1991–1991
2 sentences

1991I think a safer course is steered by rather strict adherence to the requirement that adequate findings be made by the trial court, where required under Utah R.Civ.P. 52, with the only exception being where the failure to make findings is harmless, i.e., where “the facts in the record are ‘clear, uncontroverted, and capable of supporting only findings in favor of the judgment.’ ” Acton v. Deliran, 737 P.2d 996, 999 (Utah 1987) (emphasis added) (quoting Kinkella v. Baugh, 660 P.2d 233, 236 (Utah 1983)).

1991I think a safer course is steered by rather strict adherence to the requirement that adequate findings be made by the trial court, where required under Utah R.Civ.P. 52, with the only exception being where the failure to make findings is harmless, i.e., where "the facts in the record are `clear, uncontroverted, and capable of supporting only findings in favor of the judgment.'" Acton v. Deliran, 737 P.2d 996, 999 (Utah 1987) (emphasis added) (quoting Kinkella v. Baugh, 660 P.2d 233, 236 (Utah 1983)).

11
Rowley v. Marrcrest Homeowners' Ass'ngreen
utah · 1982 · cited in 1 Utah opinions naming this issue, 1983–1983
1 sentence

1983Moreover, the purpose of the doctrine of estoppel is “to rescue from loss a party who has, without fault, been deluded into a course of action by the wrong or neglect of another.” Rowley v. Marrerest Homeowners’ Association, Utah, 656 P.2d 414, 418 (1982) (quoting Morgan v. Board of State Lands, Utah, 549 P.2d 695, 697 (1976)) (emphasis added).

11

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 (23)

CaseCitedYears
South Weber v. Cobblestone green
utahctapp · 2022
2 sentences

2022Absent a “specific statement or written 20210028-CA 11 2022 UT App 63 South Weber v. Cobblestone representation” by the government, the exception does not apply and the estoppel claim fails.

2022Absent a “specific statement or written 20210028-CA 11 2022 UT App 63 South Weber v. Cobblestone representation” by the government, the exception does not apply and the estoppel claim fails.

22022–2022
State v. Rynhart green
utahctapp · 2025
1 sentence

2025We are not challenging the plea or conviction.” 20230262-CA 23 2025 UT App 148 State v. Rynhart proposition that a criminal defense attorney is considered a state actor for purposes of an estoppel claim. ¶56 Instead, Rynhart directs our attention to Commonwealth v. Cosby, a Pennsylvania case where a prosecutor was equitably estopped from changing his position after representing that the state would not prosecute the defendant.

12025–2025
Farm Bureau v. Weston green
utahctapp · 2023
1 sentence

2023There is no indication in Speros that the judgment entered against Hiatt was in excess of the policy limits, thus triggering the need for further analysis under the duty to defend. 20180699-CA 50 2023 UT App 136 Farm Bureau v. Weston if the Illinois Rule were in effect, or if the Utah Supreme Court intended to adopt or apply that rule, there would be no need to engage in any analysis with regard to whether Amica breached the duty to indemnify because, under the estoppel rule, once it was determined that Amica had breached its duty to defend, Amica would be estopped from contesting coverage.[36

12023–2023
STATE, DEPT. OF ENV. MGMT. v. Labor Bd. green
ri · 2002
1 sentence

2015Mgmt. v. State, 799 A.2d 274 , 277 (R.I.2002) ("The doctrine of election of remedies is one that is grounded in equity and is designed to mitigate unfairness to both parties...." (emphasis added)); Barbe v. Villeneuve, 505 So.2d 1331, 1882 (Fla.1987) ("The election of remedies doctrine is an application of the doctrine of estoppel...."). +See also Am.

12015–2015
Monarrez v. Utah Department of Transportation green
utahctapp · 2014
1 sentence

2014Rather, ‚*t+his language unambiguously informed‛ Monarrez that despite UDOT’s written notice of denial sent after the deemed-denied date had passed, ‚the State was not waiving any defenses available to it under the Utah Governmental Immunity Act, nor was it excusing [him] from strictly complying with the Act’s requirements.‛ See id. (addressing an estoppel claim where the notice from the state contained identical non- waiver language).

12014–2014
Barnes v. Wood green
utahctapp · 1988
1 sentence

1990Barnes v. Wood, 750 P.2d 1226 (Utah Ct.App.1988).

11990–1990
Forsman v. Forsman green
utah · 1989
1 sentence

1989In response to plaintiffs’ first point on appeal, it should be noted that estoppel presents a question of fact, Forsman v. Forsman, 779 P.2d 218 (Utah 1989), and that it was incumbent upon plaintiffs to prove that (1) statements made by Price City were inconsistent with claims later made by it; (2) plaintiffs took reasonable action in reliance on those statements by Price City, and (3) plaintiffs would be injured if Price City were allowed to repudiate its statement.

11989–1989
City of Evanston v. Robbins green
illappct · 1969
1 sentence

1984App.2d 278 , 254 N.E.2d 536 (1969), holding that in zoning cases the doctrine of estoppel may be applied where the record suggests that the detriment to the public is negligible and there is no risk to public health or safety.

11984–1984
Township of Haverford v. Spica green
pacommwct · 1974
2 sentences

1984Other cases invoking estoppel where building permits had been issued and construction had been commenced or completed include Tankersley Brothers Industries, Inc. v. City of Fayetteville, 227 Ark. 130 , 296 S.W.2d 412 (1956); Strong v. County of Santa Cruz, 15 Cal.3d 720 , 125 Cal. Rptr. 896 , 543 P.2d 264 (1975); Township of Haverford v. Spica, 16 Pa.Cmwlth. 326 , 328 A.2d 878 (1974).

1984Other cases invoking estoppel where building permits had been issued and construction had been commenced or completed include Tankersley Brothers Industries, Inc. v. City of Fayetteville, 227 Ark. 130 , 296 S.W.2d 412 (1956); Strong v. County of Santa Cruz, 15 Cal.3d 720 , 125 Cal. Rptr. 896 , 543 P.2d 264 (1975); Township of Haverford v. Spica, 16 Pa.Cmwlth. 326 , 328 A.2d 878 (1974).

11984–1984
Strong v. County of Santa Cruz green
cal · 1975
2 sentences

1984Other cases invoking estoppel where building permits had been issued and construction had been commenced or completed include Tankersley Brothers Industries, Inc. v. City of Fayetteville, 227 Ark. 130 , 296 S.W.2d 412 (1956); Strong v. County of Santa Cruz, 15 Cal.3d 720 , 125 Cal. Rptr. 896 , 543 P.2d 264 (1975); Township of Haverford v. Spica, 16 Pa.Cmwlth. 326 , 328 A.2d 878 (1974).

1984Other cases invoking estoppel where building permits had been issued and construction had been commenced or completed include Tankersley Brothers Industries, Inc. v. City of Fayetteville, 227 Ark. 130 , 296 S.W.2d 412 (1956); Strong v. County of Santa Cruz, 15 Cal.3d 720 , 125 Cal. Rptr. 896 , 543 P.2d 264 (1975); Township of Haverford v. Spica, 16 Pa.Cmwlth. 326 , 328 A.2d 878 (1974).

11984–1984
Tankersley Bros. Industries, Inc. v. City of Fayetteville green
ark · 1956
2 sentences

1984Other cases invoking estoppel where building permits had been issued and construction had been commenced or completed include Tankersley Brothers Industries, Inc. v. City of Fayetteville, 227 Ark. 130 , 296 S.W.2d 412 (1956); Strong v. County of Santa Cruz, 15 Cal.3d 720 , 125 Cal. Rptr. 896 , 543 P.2d 264 (1975); Township of Haverford v. Spica, 16 Pa.Cmwlth. 326 , 328 A.2d 878 (1974).

1984Other cases invoking estoppel where building permits had been issued and construction had been commenced or completed include Tankersley Brothers Industries, Inc. v. City of Fayetteville, 227 Ark. 130 , 296 S.W.2d 412 (1956); Strong v. County of Santa Cruz, 15 Cal.3d 720 , 125 Cal. Rptr. 896 , 543 P.2d 264 (1975); Township of Haverford v. Spica, 16 Pa.Cmwlth. 326 , 328 A.2d 878 (1974).

11984–1984
Migliaccio v. Davis green
utah · 1951
2 sentences

1973As to other statements of the estoppel principle see Grover v. Garn, 23 Utah 2d 441 , 464 P.2d 598 (1970); Migliaccio v. Davis, 120 Utah 1 , 232 P.2d 195 (1951). 4 .

1973As to other statements of the estoppel principle see Grover v. Garn, 23 Utah 2d 441 , 464 P.2d 598 (1970); Migliaccio v. Davis, 120 Utah 1 , 232 P.2d 195 (1951). 4 .

11973–1973
Grover v. Garn green
utah · 1970
2 sentences

1973As to other statements of the estoppel principle see Grover v. Garn, 23 Utah 2d 441 , 464 P.2d 598 (1970); Migliaccio v. Davis, 120 Utah 1 , 232 P.2d 195 (1951). 4 .

1973As to other statements of the estoppel principle see Grover v. Garn, 23 Utah 2d 441 , 464 P.2d 598 (1970); Migliaccio v. Davis, 120 Utah 1 , 232 P.2d 195 (1951). 4 .

11973–1973
Perkins v. Spencer green
utah · 1952
2 sentences

1973Jensen v. Nielsen, 26 Utah 2d 96 , 485 P.2d 673 (1971); Perkins v. Spencer, 121 Utah 468 , 243 P.2d 446 (1952); Malmberg v. Baugh, 62 Utah 331 , 218 P. 975 (1923). 5 .

1973Jensen v. Nielsen, 26 Utah 2d 96 , 485 P.2d 673 (1971); Perkins v. Spencer, 121 Utah 468 , 243 P.2d 446 (1952); Malmberg v. Baugh, 62 Utah 331 , 218 P. 975 (1923). 5 .

11973–1973
Jensen v. Nielsen green
utah · 1971
2 sentences

1973Jensen v. Nielsen, 26 Utah 2d 96 , 485 P.2d 673 (1971); Perkins v. Spencer, 121 Utah 468 , 243 P.2d 446 (1952); Malmberg v. Baugh, 62 Utah 331 , 218 P. 975 (1923). 5 .

1973Jensen v. Nielsen, 26 Utah 2d 96 , 485 P.2d 673 (1971); Perkins v. Spencer, 121 Utah 468 , 243 P.2d 446 (1952); Malmberg v. Baugh, 62 Utah 331 , 218 P. 975 (1923). 5 .

11973–1973
Malmberg v. Baugh green
utah · 1923
2 sentences

1973Jensen v. Nielsen, 26 Utah 2d 96 , 485 P.2d 673 (1971); Perkins v. Spencer, 121 Utah 468 , 243 P.2d 446 (1952); Malmberg v. Baugh, 62 Utah 331 , 218 P. 975 (1923). 5 .

1973Jensen v. Nielsen, 26 Utah 2d 96 , 485 P.2d 673 (1971); Perkins v. Spencer, 121 Utah 468 , 243 P.2d 446 (1952); Malmberg v. Baugh, 62 Utah 331 , 218 P. 975 (1923). 5 .

11973–1973
Price v. Price green
utah · 1955
2 sentences

1956NOTES [1] Openshaw v. Openshaw, 105 Utah 574, 579 , 144 P.2d 528 . [2] Price v. Price, 4 Utah 2d 153 , 289 P.2d 1044 .

1956NOTES [1] Openshaw v. Openshaw, 105 Utah 574, 579 , 144 P.2d 528 . [2] Price v. Price, 4 Utah 2d 153 , 289 P.2d 1044 .

11956–1956
Openshaw v. Openshaw green
utah · 1943
2 sentences

1956NOTES [1] Openshaw v. Openshaw, 105 Utah 574, 579 , 144 P.2d 528 . [2] Price v. Price, 4 Utah 2d 153 , 289 P.2d 1044 .

1956NOTES [1] Openshaw v. Openshaw, 105 Utah 574, 579 , 144 P.2d 528 . [2] Price v. Price, 4 Utah 2d 153 , 289 P.2d 1044 .

11956–1956
Free v. Farnworth green
utah · 1943
11949–1949
Barber v. Anderson green
utah · 1929
11942–1942
Schulenbarger v. Johnstone neutral
wash · 1911
11936–1936
Veysey Bros. v. Bishop Mill Co. neutral
wash · 1911
11936–1936
Riley v. Quigley neutral
ill · 1869
11921–1921

Where else courts name it

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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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