rationale behind rule (Utah) · Go Syfert
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rationale behind rule in Utah

11 Utah opinions name it 2 courts 1989–2021 1 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 (8)

CaseFollowedCited
Gardner v. Gardnergreen
utah · 1988 · cited in 2 Utah opinions naming this issue, 1990–1992
2 sentences

1992The rationale behind this exception to the general rule is that “[m]arital property ‘encompasses all of the assets of every nature possessed by the parties, whenever obtained and from whatever source derived,’ ” Sorensen v. Sorensen, 769 P.2d 820, 824 (Utah App.1989) (quoting Gardner v. Gardner, 748 P.2d 1076, 1078 (Utah 1988)), and that the trial court may, in the exercise of its broad discretion, divide the property equitably regardless of its source or time of acquisition.

1990The rationale behind this exception to the general rule is that "[m]arital property 'encompasses all of the assets of every nature possessed by the parties, whenever obtained and from whatever source derived,’ ” Sorensen v. Sorensen, 169 P.2d 820, 824 (Utah Ct.App.1989) (quoting Gardner v. Gardner, 748 P.2d 1076, 1078 (Utah 1988)), and that the trial court may, in the exercise of its broad discretion, divide the property equitably, regardless of its source or time of acquisition.

22
Eagle Mountain City v. Parsons Kinghorn & Harris, P.C.green
utah · 2017 · cited in 1 Utah opinions naming this issue, 2021–2021
2 sentences

2021The rationale behind this rule is rooted in a “strong presumption of freedom of contract,” which also allows contracts to be voided if the contract “violates a clear and compelling public policy” or a “well-defined and dominant policy.” Id. ¶ 15 & n.7 (citations omitted). ¶124 In definitively holding that legal malpractice claims are presumed voluntarily assignable absent circumstances that clearly violate public policy, we noted that Snow, Nuffer, Engstrom & Drake v. Tanasse had “already recognized that the involuntary assignment of [legal malpractice] claims . . . does not violate public pol

2021The rationale behind this rule is rooted in a “strong presumption of freedom of contract,” which also allows contracts to be voided if the contract “violates a clear and compelling public policy” or a “well-defined and dominant policy.” Id. ¶ 15 & n.7 (citations omitted). ¶124 In definitively holding that legal malpractice claims are presumed voluntarily assignable absent circumstances that clearly violate public policy, we noted that Snow, Nuffer, Engstrom & Drake v. Tanasse had “already recognized that the involuntary assignment of [legal malpractice] claims . . . does not violate public pol

11
Boucher Ex Rel. Boucher v. Dixie Medical Centergreen
utah · 1992 · cited in 1 Utah opinions naming this issue, 2018–2018
1 sentence

2018See, e.g. , id. at 242 (rejecting the Dillon framework for bystander recovery based on foreseeability and holding that a plaintiff "who feared for her own safety but was not objectively within the zone of danger created by the defendants' breach of duty[ ] may not recover for emotional distress caused by her fright"); Boucher , 850 P.2d at 1182 (declining to adopt modifications of the Dillon rule and noting that our court had "unequivocally ... rejected any approach that allows plaintiffs who are not within the zone of danger to recover for emotional distress caused by witnessing another's inj

11
Hansen v. Sea Ray Boats, Inc.green
utah · 1992 · cited in 1 Utah opinions naming this issue, 2018–2018
1 sentence

2018See, e.g. , id. at 242 (rejecting the Dillon framework for bystander recovery based on foreseeability and holding that a plaintiff "who feared for her own safety but was not objectively within the zone of danger created by the defendants' breach of duty[ ] may not recover for emotional distress caused by her fright"); Boucher , 850 P.2d at 1182 (declining to adopt modifications of the Dillon rule and noting that our court had "unequivocally ... rejected any approach that allows plaintiffs who are not within the zone of danger to recover for emotional distress caused by witnessing another's inj

11
State v. Menziesgreen
utah · 1994 · cited in 1 Utah opinions naming this issue, 2005–2005
1 sentence

2005Id. at 506-07.

11
In Re Piper Aircraft Distribution System Antitrust Litigation. Van-S-Aviation Corporation v. Piper Aircraft Corporationgreen
ca8 · 1977 · cited in 1 Utah opinions naming this issue, 1994–1994
1 sentence

1994Antitrust Litig., 551 F.2d 213, 219 (8th Cir.1977).

11
Donald Yoffe v. Keller Industries, Inc., a Corporation and Henry A. Keller and Norman S. Edelcup, Individualsgreen
ca5 · 1978 · cited in 1 Utah opinions naming this issue, 1994–1994
1 sentence

1994Ry., 668 F.2d 369 (8th Cir.1981), ce rt. denied, 456 U.S. 946 , 102 S.Ct. 2013 , 72 L.Ed.2d 469 (1982); Yoffe v. Keller Indus., Inc., 580 F.2d 126, 129 (5th Cir.1978), cert. denied, 440 U.S. 915 , 99 S.Ct. 1231 , 59 L.Ed.2d 464 (1979). 5 The rationale behind this rule is that a voluntary dismissal without prejudice “render[s] the proceedings a nullity and leave[s] the parties as if the action had never been brought.” In re Piper Aircraft Distribution Sys.

11
Sorensen v. Sorensengreen
utahctapp · 1989 · cited in 1 Utah opinions naming this issue, 1992–1992
1 sentence

1992The rationale behind this exception to the general rule is that “[m]arital property ‘encompasses all of the assets of every nature possessed by the parties, whenever obtained and from whatever source derived,’ ” Sorensen v. Sorensen, 769 P.2d 820, 824 (Utah App.1989) (quoting Gardner v. Gardner, 748 P.2d 1076, 1078 (Utah 1988)), and that the trial court may, in the exercise of its broad discretion, divide the property equitably regardless of its source or time of acquisition.

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 (14)

CaseCitedYears
Snow, Nuffer, Engstrom & Drake v. Tanasse green
utah · 1999
2 sentences

2021The rationale behind this rule is rooted in a “strong presumption of freedom of contract,” which also allows contracts to be voided if the contract “violates a clear and compelling public policy” or a “well-defined and dominant policy.” Id. ¶ 15 & n.7 (citations omitted). ¶124 In definitively holding that legal malpractice claims are presumed voluntarily assignable absent circumstances that clearly violate public policy, we noted that Snow, Nuffer, Engstrom & Drake v. Tanasse had “already recognized that the involuntary assignment of [legal malpractice] claims . . . does not violate public pol

2021The rationale behind this rule is rooted in a “strong presumption of freedom of contract,” which also allows contracts to be voided if the contract “violates a clear and compelling public policy” or a “well-defined and dominant policy.” Id. ¶ 15 & n.7 (citations omitted). ¶124 In definitively holding that legal malpractice claims are presumed voluntarily assignable absent circumstances that clearly violate public policy, we noted that Snow, Nuffer, Engstrom & Drake v. Tanasse had “already recognized that the involuntary assignment of [legal malpractice] claims . . . does not violate public pol

12021–2021
McRae & DeLand v. Feltch green
utah · 1983
1 sentence

2019The court noted that the rationale behind this rule "is to prohibit piecemeal litigation ... and to prevent the needless proliferation of litigation." Id.

12019–2019
Straub v. Fisher and Paykel Health Care green
utah · 1999
2 sentences

2018See, e.g. , id. at 242 (rejecting the Dillon framework for bystander recovery based on foreseeability and holding that a plaintiff "who feared for her own safety but was not objectively within the zone of danger created by the defendants' breach of duty[ ] may not recover for emotional distress caused by her fright"); Boucher , 850 P.2d at 1182 (declining to adopt modifications of the Dillon rule and noting that our court had "unequivocally ... rejected any approach that allows plaintiffs who are not within the zone of danger to recover for emotional distress caused by witnessing another's inj

2018See, e.g. , id. at 242 (rejecting the Dillon framework for bystander recovery based on foreseeability and holding that a plaintiff "who feared for her own safety but was not objectively within the zone of danger created by the defendants' breach of duty[ ] may not recover for emotional distress caused by her fright"); Boucher , 850 P.2d at 1182 (declining to adopt modifications of the Dillon rule and noting that our court had "unequivocally ... rejected any approach that allows plaintiffs who are not within the zone of danger to recover for emotional distress caused by witnessing another's inj

12018–2018
Nebeker v. Utah State Tax Commission green
utah · 2001
1 sentence

2009The rationale behind this rule permits courts to avoid "procedural confusion and piecemeal litigation." Id. 119 .

12009–2009
International Paper Company v. Schwabedissen Maschinen & Anlagen Gmbh green
ca4 · 2000
1 sentence

2006Id. at 418 .

12006–2006
Webb v. Interstate Land Corp. green
utah · 1996
1 sentence

2001Id. at 1192 . 122 However, under the U.C0.C., a real estate interest arising from a purchase materially differs from an interest arising from a judgment lien.

12001–2001
Curlee Bowers v. St. Louis Southwestern Railway Company, a Corporation green
ca8 · 1981
1 sentence

1994Ry., 668 F.2d 369 (8th Cir.1981), ce rt. denied, 456 U.S. 946 , 102 S.Ct. 2013 , 72 L.Ed.2d 469 (1982); Yoffe v. Keller Indus., Inc., 580 F.2d 126, 129 (5th Cir.1978), cert. denied, 440 U.S. 915 , 99 S.Ct. 1231 , 59 L.Ed.2d 464 (1979). 5 The rationale behind this rule is that a voluntary dismissal without prejudice “render[s] the proceedings a nullity and leave[s] the parties as if the action had never been brought.” In re Piper Aircraft Distribution Sys.

11994–1994
Economy Carpets Manufacturers & Distributors, Inc. v. Better Business Bureau of Baton Rouge Area, Inc. green
scotus · 1979
1 sentence

1994Ry., 668 F.2d 369 (8th Cir.1981), ce rt. denied, 456 U.S. 946 , 102 S.Ct. 2013 , 72 L.Ed.2d 469 (1982); Yoffe v. Keller Indus., Inc., 580 F.2d 126, 129 (5th Cir.1978), cert. denied, 440 U.S. 915 , 99 S.Ct. 1231 , 59 L.Ed.2d 464 (1979). 5 The rationale behind this rule is that a voluntary dismissal without prejudice “render[s] the proceedings a nullity and leave[s] the parties as if the action had never been brought.” In re Piper Aircraft Distribution Sys.

11994–1994
Altbaum v. California green
scotus · 1979
1 sentence

1994Ry., 668 F.2d 369 (8th Cir.1981), ce rt. denied, 456 U.S. 946 , 102 S.Ct. 2013 , 72 L.Ed.2d 469 (1982); Yoffe v. Keller Indus., Inc., 580 F.2d 126, 129 (5th Cir.1978), cert. denied, 440 U.S. 915 , 99 S.Ct. 1231 , 59 L.Ed.2d 464 (1979). 5 The rationale behind this rule is that a voluntary dismissal without prejudice “render[s] the proceedings a nullity and leave[s] the parties as if the action had never been brought.” In re Piper Aircraft Distribution Sys.

11994–1994
Illinois Bell Telephone Co. v. Getto green
scotus · 1982
1 sentence

1994Ry., 668 F.2d 369 (8th Cir.1981), ce rt. denied, 456 U.S. 946 , 102 S.Ct. 2013 , 72 L.Ed.2d 469 (1982); Yoffe v. Keller Indus., Inc., 580 F.2d 126, 129 (5th Cir.1978), cert. denied, 440 U.S. 915 , 99 S.Ct. 1231 , 59 L.Ed.2d 464 (1979). 5 The rationale behind this rule is that a voluntary dismissal without prejudice “render[s] the proceedings a nullity and leave[s] the parties as if the action had never been brought.” In re Piper Aircraft Distribution Sys.

11994–1994
Bowers v. St. Louis Southwestern Railway Co. green
scotus · 1982
1 sentence

1994Ry., 668 F.2d 369 (8th Cir.1981), ce rt. denied, 456 U.S. 946 , 102 S.Ct. 2013 , 72 L.Ed.2d 469 (1982); Yoffe v. Keller Indus., Inc., 580 F.2d 126, 129 (5th Cir.1978), cert. denied, 440 U.S. 915 , 99 S.Ct. 1231 , 59 L.Ed.2d 464 (1979). 5 The rationale behind this rule is that a voluntary dismissal without prejudice “render[s] the proceedings a nullity and leave[s] the parties as if the action had never been brought.” In re Piper Aircraft Distribution Sys.

11994–1994
Calhoun v. United States green
scotus · 1982
1 sentence

1994Ry., 668 F.2d 369 (8th Cir.1981), ce rt. denied, 456 U.S. 946 , 102 S.Ct. 2013 , 72 L.Ed.2d 469 (1982); Yoffe v. Keller Indus., Inc., 580 F.2d 126, 129 (5th Cir.1978), cert. denied, 440 U.S. 915 , 99 S.Ct. 1231 , 59 L.Ed.2d 464 (1979). 5 The rationale behind this rule is that a voluntary dismissal without prejudice “render[s] the proceedings a nullity and leave[s] the parties as if the action had never been brought.” In re Piper Aircraft Distribution Sys.

11994–1994
Noble v. Noble green
utah · 1988
1 sentence

1990Noble, 761 P.2d at 1373 .

11990–1990
People v. Superior Court green
cal · 1970
2 sentences

1989The rationale behind this rule is articulated by the court in People v. Superior Court of Yolo County, 3 Cal.3d 807 , 91 Cal.Rptr. 729 , 478 P.2d 449 (1970): [Fjrom the viewpoint of the observer, an innocent gesture can often be mistaken for a guilty movement.

1989The rationale behind this rule is articulated by the court in People v. Superior Court of Yolo County, 3 Cal.3d 807 , 91 Cal.Rptr. 729 , 478 P.2d 449 (1970): [Fjrom the viewpoint of the observer, an innocent gesture can often be mistaken for a guilty movement.

11989–1989

Where else courts name it

IL 127 (1972–2026) CA 103 (1961–2025) OH 87 (1956–2026) IN 80 (1978–2025) TX 79 (1964–2022) PA 67 (1965–2024) AR 47 (1982–2026) FL 42 (1971–2024) AL 36 (1980–2025) NY 35 (1930–2024) TN 34 (1981–2025) MD 28 (1978–2025) LA 28 (1980–2024) WA 28 (1972–2026) MI 25 (1975–2016) IA 25 (1967–2025) MO 25 (1980–2021) WV 24 (1978–2024) MS 23 (1985–2023) AZ 21 (1969–2021) CT 21 (1974–2025) MT 20 (1969–2022) KY 18 (1979–2024) KS 18 (1975–2025) MA 17 (1979–2025) OR 17 (1975–2026) RI 16 (1984–2024) NC 15 (1980–2025) VA 15 (1993–2022) NM 14 (1989–2025) CO 13 (1976–2022) WI 13 (1963–2017) NH 12 (1991–2023) OK 11 (1981–2002) DC 11 (1977–2004) UT 11 (1989–2021) ID 10 (1991–2025) GA 10 (1978–2022) NJ 9 (1965–2015) ME 9 (1975–2020) SC 8 (1989–2025) AK 7 (1979–1994) SD 7 (1986–2016) WY 7 (1983–2020) HI 6 (1998–2021) MN 5 (1956–2017) NE 4 (1982–2007) VT 3 (2023–2024) DE 3 (1975–1980) NV 2 (1984–1992) ND 2 (2009–2009)

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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