timeliness rule (Utah) · Go Syfert
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timeliness rule in Utah

13 Utah opinions name it 2 courts 1937–2017 0 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
State v. Johnsongreen
utahctapp · 2013 · cited in 1 Utah opinions naming this issue, 2017–2017
2 sentences

2017See State v. Johnson , 2013 UT App 276 , ¶ 8, 316 P.3d 994 (holding untimely a challenge based on counsel's failure to object to the continuance of trial, because the timeliness requirement "prevents defendants from sandbagging the prosecution by waiting until the only available remedy for the alleged error is outright dismissal or a new trial" (citation and internal quotation marks omitted)).

2017See State v. Johnson , 2013 UT App 276 , ¶ 8, 316 P.3d 994 (holding untimely a challenge based on counsel's failure to object to the continuance of trial, because the timeliness requirement "prevents defendants from sandbagging the prosecution by waiting until the only available remedy for the alleged error is outright dismissal or a new trial" (citation and internal quotation marks omitted)).

11
State v. Browngreen
utahctapp · 1993 · cited in 1 Utah opinions naming this issue, 2013–2013
1 sentence

2013The timeliness requirement is "a pre-condition to appellate review because entertaining belatedly raised issues sanction[s] the practice of withholding positions that should properly be presented to the trial court but which may be withheld for the purpose of seeking a reversal on appeal and a new trial or dismissal." State v. Brown, 856 P.2d 358, 361-62 (Utah Ct.App. 1993) (alteration in original) (citation and internal quotation marks omitted).

11
State v. Stanfordgreen
orctapp · 1992 · cited in 1 Utah opinions naming this issue, 2013–2013
1 sentence

2013Intermountain Power Agency, 828 P.2d 459, 461 (Utah 1991), and before entry of judgment or dismissal, see Jenner, 659 P.2d at 1074 .

11
State v. Cantugreen
utah · 1988 · cited in 1 Utah opinions naming this issue, 2006–2006
1 sentence

2006Id. at 592-93, 596. *1230 ¶ 33 However, in Redd v. Negley, 785 P.2d 1098 (Utah 1989), the timeliness of a challenge to the composition of the jury was squarely before the court.

11
Busche v. Salt Lake Countygreen
utahctapp · 2001 · cited in 1 Utah opinions naming this issue, 2005–2005
2 sentences

2005See Busche v. Salt Lake County, 2001 UT App 111,¶6 , 26 P.3d 862 (discussing Utah's liberal standards for the construction of pleading language). ¶12 The question of whether EMS's motion was dilatory is a closer one. "[A] party's rule 56(f) motion for a continuance is not dilatory if the party has already initiated discovery proceedings, diligently seeks access to information that is within the sole control of the adverse party, and is denied an adequate opportunity to conduct the desired discovery." Western Dairymen, 2002 UT 39 at ¶27 ; see also Crossland Sav., 877 P.2d at 1243-44 (addressing

2005See Busche v. Salt Lake County, 2001 UT App 111,¶6 , 26 P.3d 862 (discussing Utah's liberal standards for the construction of pleading language). ¶12 The question of whether EMS's motion was dilatory is a closer one. "[A] party's rule 56(f) motion for a continuance is not dilatory if the party has already initiated discovery proceedings, diligently seeks access to information that is within the sole control of the adverse party, and is denied an adequate opportunity to conduct the desired discovery." Western Dairymen, 2002 UT 39 at ¶27 ; see also Crossland Sav., 877 P.2d at 1243-44 (addressing

11
Salt Lake County v. Western Dairymen Cooperative, Inc.green
utah · 2002 · cited in 1 Utah opinions naming this issue, 2005–2005
1 sentence

2005See Busche v. Salt Lake County, 2001 UT App 111,¶6 , 26 P.3d 862 (discussing Utah's liberal standards for the construction of pleading language). ¶12 The question of whether EMS's motion was dilatory is a closer one. "[A] party's rule 56(f) motion for a continuance is not dilatory if the party has already initiated discovery proceedings, diligently seeks access to information that is within the sole control of the adverse party, and is denied an adequate opportunity to conduct the desired discovery." Western Dairymen, 2002 UT 39 at ¶27 ; see also Crossland Sav., 877 P.2d at 1243-44 (addressing

11
Strand v. Associated Students of the University of Utahgreen
utah · 1977 · cited in 1 Utah opinions naming this issue, 2005–2005
1 sentence

2005See Busche v. Salt Lake County, 2001 UT App 111,¶6 , 26 P.3d 862 (discussing Utah's liberal standards for the construction of pleading language). ¶12 The question of whether EMS's motion was dilatory is a closer one. "[A] party's rule 56(f) motion for a continuance is not dilatory if the party has already initiated discovery proceedings, diligently seeks access to information that is within the sole control of the adverse party, and is denied an adequate opportunity to conduct the desired discovery." Western Dairymen, 2002 UT 39 at ¶27 ; see also Crossland Sav., 877 P.2d at 1243-44 (addressing

11
Crossland Savings v. Hatchgreen
utah · 1994 · cited in 1 Utah opinions naming this issue, 2005–2005
1 sentence

2005See Busche v. Salt Lake County, 2001 UT App 111,¶6 , 26 P.3d 862 (discussing Utah's liberal standards for the construction of pleading language). ¶12 The question of whether EMS's motion was dilatory is a closer one. "[A] party's rule 56(f) motion for a continuance is not dilatory if the party has already initiated discovery proceedings, diligently seeks access to information that is within the sole control of the adverse party, and is denied an adequate opportunity to conduct the desired discovery." Western Dairymen, 2002 UT 39 at ¶27 ; see also Crossland Sav., 877 P.2d at 1243-44 (addressing

11
Cox v. Wintersgreen
utah · 1984 · cited in 1 Utah opinions naming this issue, 2005–2005
1 sentence

2005See Busche v. Salt Lake County, 2001 UT App 111,¶6 , 26 P.3d 862 (discussing Utah's liberal standards for the construction of pleading language). ¶12 The question of whether EMS's motion was dilatory is a closer one. "[A] party's rule 56(f) motion for a continuance is not dilatory if the party has already initiated discovery proceedings, diligently seeks access to information that is within the sole control of the adverse party, and is denied an adequate opportunity to conduct the desired discovery." Western Dairymen, 2002 UT 39 at ¶27 ; see also Crossland Sav., 877 P.2d at 1243-44 (addressing

11
State v. Leegreen
utah · 1981 · cited in 1 Utah opinions naming this issue, 1993–1993
1 sentence

1993Utah courts consider timeliness a pre-condition to appellate review because entertaining belatedly raised issues “sanction[s] the *362 practice of withholding positions that should properly be presented to the trial court but which may be withheld for the purpose of seeking a reversal on appeal and a new trial or dismissal.” State v. Lee, 633 P.2d 48, 53 (Utah 1981); State v. Webb, 790 P.2d 65, 78 (Utah App.1990).

11
State v. Webbgreen
utahctapp · 1990 · cited in 1 Utah opinions naming this issue, 1993–1993
1 sentence

1993Utah courts consider timeliness a pre-condition to appellate review because entertaining belatedly raised issues “sanction[s] the *362 practice of withholding positions that should properly be presented to the trial court but which may be withheld for the purpose of seeking a reversal on appeal and a new trial or dismissal.” State v. Lee, 633 P.2d 48, 53 (Utah 1981); State v. Webb, 790 P.2d 65, 78 (Utah App.1990).

11
Klein v. Kleingreen
utah · 1975 · cited in 1 Utah opinions naming this issue, 1985–1985
1 sentence

1985See also Klein, 544 P.2d at 476 (withdrawal one day after stipulation in divorce action rejected where trial court considered decree just and reasonable).

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 (8)

CaseCitedYears
Sanpete America, LLC v. Willardsen green
utah · 2011
2 sentences

2017A district court judge "err[s] as a matter of law in granting [an] untimely rule 59 motion." Sanpete Am., LLC v. Willardsen , 2011 UT 48 , ¶ 66, 269 P.3d 118 .

2017A district court judge "err[s] as a matter of law in granting [an] untimely rule 59 motion." Sanpete Am., LLC v. Willardsen , 2011 UT 48 , ¶ 66, 269 P.3d 118 .

22017–2017
Craig v. Provo City green
utah · 2016
1 sentence

2016The Governmental Immunity Act charts a middle course between the parties’ positions: The Act is neither perfectly all-encompassing nor entirely open to supplementation; it is all-encompassing as to the terms of the (continued…) 10 Cite as: 2016 UT 40 Opinion of the Court standards that dictate the timeliness of a claim asserted against the government.

12016–2016
Jenner v. Real Estate Services green
utah · 1983
2 sentences

2013The timeliness requirement is designed to minimize interference with "the rights of existing parties" and "the orderly processes of the court." Id. at 1074 . 124 Generally, a motion to intervene is timely if it is filed before the "final settlement of all issues by all parties," see Millard Cnty. v. Utah State Tax Comm'n ex rel.

2013Intermountain Power Agency, 828 P.2d 459, 461 (Utah 1991), and before entry of judgment or dismissal, see Jenner, 659 P.2d at 1074 .

12013–2013
State v. Winfield green
utah · 2006
2 sentences

2012To the extent that the Restoration Network did raise the claim, its argument was "so eryptic and vague that [it] did not satisfy the [preservation rule's] specificity requirement." State v. Winfield, 2006 UT 4, ¶ 27 , 128 P.3d 1171 . 1146 The Restoration Network argues that it also preserved its claim regarding the timeliness of the hearing in its Objection to Revised Proposed Order of Judgment.

2012To the extent that the Restoration Network did raise the claim, its argument was "so eryptic and vague that [it] did not satisfy the [preservation rule's] specificity requirement." State v. Winfield, 2006 UT 4, ¶ 27 , 128 P.3d 1171 . 1146 The Restoration Network argues that it also preserved its claim regarding the timeliness of the hearing in its Objection to Revised Proposed Order of Judgment.

12012–2012
Harley Davidson v. Workforce Appeals Board of the Utah Department of Workforce Services green
utah · 2005
2 sentences

2006Harley Davidson of N. Utah v. Workforce Appeals Bd., 2005 UT 38, ¶ 16 , 116 P.3d 349 . 115 In this case, it is undisputed that plaintiffs fulfilled this jurisdictional requirement by filing a timely notice of appeal.

2006Harley Davidson of N. Utah v. Workforce Appeals Bd., 2005 UT 38, ¶ 16 , 116 P.3d 349 . 115 In this case, it is undisputed that plaintiffs fulfilled this jurisdictional requirement by filing a timely notice of appeal.

12006–2006
Redd v. Negley green
utah · 1989
1 sentence

2006Id. at 592-93, 596. *1230 ¶ 33 However, in Redd v. Negley, 785 P.2d 1098 (Utah 1989), the timeliness of a challenge to the composition of the jury was squarely before the court.

12006–2006
State v. Bankhead green
utah · 1986
1 sentence

2006Furthermore, a survey of Utah law indicates that it is a well established principle that Batson challenges must be raised both before the jury is sworn and before the remainder of the venire is dismissed in order to be deemed timely. ¶27 In State v. Bankhead, 727 P.2d 216 (Utah 1986), a case decided by this court prior to Batson , we considered the timeliness of a challenge to the composition of the jury.

12006–2006
National Grocery Co. v. Pratt-Low Preserving Co. neutral
wash · 1932
2 sentences

1937National Grocery Co. v. Pratt-Low Preserving Co., 170 Wash. 575 , 17 P. (2d) 51, 54 , In this latter case the facts are somewhat similar to those in the instant case.

1937National Grocery Co. v. Pratt-Low Preserving Co., 170 Wash. 575 , 17 P. (2d) 51, 54 , In this latter case the facts are somewhat similar to those in the instant case.

11937–1937

Where else courts name it

PA 1486 (1977–2026) CA 110 (1974–2026) NY 71 (1972–2026) OH 58 (1984–2026) IL 49 (1975–2026) TX 32 (1972–2025) AZ 27 (1979–2022) CT 22 (1982–2016) NM 19 (1988–2024) MO 19 (1992–2023) FL 16 (1985–2025) UT 13 (1937–2017) MD 13 (1992–2011) WA 13 (1984–2024) IA 12 (1979–2026) AL 12 (1983–2024) TN 12 (2010–2026) CO 10 (1984–2026) AR 10 (1994–2024) MA 9 (1985–2022) IN 9 (2013–2025) DE 9 (1997–2026) GA 9 (1973–2026) NJ 8 (1979–2021) MN 8 (1975–2015) OR 7 (1977–2018) MT 6 (2001–2015) ID 6 (1993–2015) LA 6 (1991–2016) MI 5 (1992–2006) KS 5 (1980–2021) WI 5 (1980–2019) NC 4 (2006–2025) VA 4 (2007–2026) MS 4 (2006–2017) WV 4 (2012–2024) NH 4 (1992–2003) HI 3 (2015–2021) VT 3 (2005–2025) WY 3 (2001–2021) NV 3 (2016–2023) SC 3 (2009–2019) VI 3 (2012–2014) RI 3 (2003–2014) ME 2 (2009–2025) DC 2 (1996–2022) AK 2 (1974–1987) SD 2 (1990–2009)

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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