reliance requirement (Utah) · Go Syfert
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reliance requirement in Utah

8 Utah opinions name it 2 courts 1995–2026 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 (4)

CaseFollowedCited
Orton v. Cartergreen
utah · 1998 · cited in 1 Utah opinions naming this issue, 2006–2006
1 sentence

2006Because we uphold the trial court’s decision on other grounds, the trial court's reliance on rule 37(f) is harmless error. "[A]n appellate court may affirm a judgment, order, or decree appealed from if it is sustainable on any legal ground or theory apparent on the record,’ even though that ground or theory was not identified by the lower court as the basis of its ruling.” Orton v. Carter, 970 P.2d 1254, 1260 (Utah 1998) (quoting Limb v. Federated Milk Producers Ass’n, 23 Utah 2d 222 , 461 P.2d 290 , 293 n. 2 (1969)). .

11
Gustafson v. Alloyd Co.green
scotus · 1995 · cited in 1 Utah opinions naming this issue, 1996–1996
2 sentences

1996Second, our decision is consistent with federal courts' refusal to hold that section 12(2) of the Securities Act of 1933, the federal analog to section 61-1-22, contains a reliance requirement. [7] See, e.g., Woodward v. Wright, 266 F.2d 108, 116 (10th Cir.1959); see also Gustafson v. Alloyd Co., ___ U.S. ___, ___, 115 S.Ct. 1061, 1070 , 131 L.Ed.2d 1 (1995) (recognizing "Congress' decision in § 12(2) to grant buyers a right to rescind without proof of reliance"); Louis Loss, Fundamentals of Securities Regulation 889 (1988) (noting that reliance is not element of section 12(2) cause of action)

1996Second, our decision is consistent with federal courts' refusal to hold that section 12(2) of the Securities Act of 1933, the federal analog to section 61-1-22, contains a reliance requirement. [7] See, e.g., Woodward v. Wright, 266 F.2d 108, 116 (10th Cir.1959); see also Gustafson v. Alloyd Co., ___ U.S. ___, ___, 115 S.Ct. 1061, 1070 , 131 L.Ed.2d 1 (1995) (recognizing "Congress' decision in § 12(2) to grant buyers a right to rescind without proof of reliance"); Louis Loss, Fundamentals of Securities Regulation 889 (1988) (noting that reliance is not element of section 12(2) cause of action)

11
Woodward v. Wrightgreen
ca10 · 1959 · cited in 1 Utah opinions naming this issue, 1996–1996
2 sentences

1996Second, our decision is consistent with federal courts' refusal to hold that section 12(2) of the Securities Act of 1933, the federal analog to section 61-1-22, contains a reliance requirement. [7] See, e.g., Woodward v. Wright, 266 F.2d 108, 116 (10th Cir.1959); see also Gustafson v. Alloyd Co., ___ U.S. ___, ___, 115 S.Ct. 1061, 1070 , 131 L.Ed.2d 1 (1995) (recognizing "Congress' decision in § 12(2) to grant buyers a right to rescind without proof of reliance"); Louis Loss, Fundamentals of Securities Regulation 889 (1988) (noting that reliance is not element of section 12(2) cause of action)

1996Second, our decision is consistent with federal courts’ refusal to hold that section 12(2) of the Securities Act of 1933, the federal analog to section 61-1-22, contains a reliance requirement. 7 See, e.g., Woodward v. Wright, 266 F.2d 108, 116 (10th Cir.1959); see also Gustafson v. Alloyd Co., — U.S. -, -, 115 S.Ct. 1061, 1070 , 131 L.Ed.2d 1 (1995) (recognizing “Congress’ decision in § 12(2) to grant buyers a right to rescind without proof of reliance”); Louis Loss, Fundamentals of Securities Regulation 889 (1988) (noting that reliance is not element of section 12(2) cause of action).

11
American Coal Co. v. Sandstromgreen
utah · 1984 · cited in 1 Utah opinions naming this issue, 1996–1996
2 sentences

1996See American Coal Co. v. Sandstrom, 689 P.2d 1, 3 (Utah 1984) ("Where the legislature amends a portion of a statute, leaving other portions unamended,... absent substantial evidence to the contrary, the legislature is presumed to have been satisfied with prior judicial constructions of the unaltered portions of the statute and to have adopted those constructions as consistent with its own intent.").

1996See American Coal Co. v. Sandstrom, 689 P.2d 1, 3 (Utah 1984) (“Where the legislature amends a portion of a statute, leaving other portions unamended, ... absent substantial evidence to the contrary, the legislature is presumed to have been satisfied with prior judicial constructions of the unaltered portions of the statute and to have adopted those constructions as consistent with its own intent.”).

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 (9)

CaseCitedYears
State v. Nelson-Waggoner green
utah · 2004
2 sentences

2011We do not consider issues raised " 'for the first time on appeal unless the [district] court committed plain error or exceptional circumstances exist.'" State v. Pinder, 2005 UT 15, ¶ 45 , 114 P.3d 551 (quoting State v. Nelson-Waggoner, 2004 UT 29, ¶ 16 , 94 P.3d 186 ).

2011We do not consider issues raised " 'for the first time on appeal unless the [district] court committed plain error or exceptional circumstances exist.'" State v. Pinder, 2005 UT 15, ¶ 45 , 114 P.3d 551 (quoting State v. Nelson-Waggoner, 2004 UT 29, ¶ 16 , 94 P.3d 186 ).

22011–2011
State v. Pinder green
utah · 2005
2 sentences

2011We do not consider issues raised " 'for the first time on appeal unless the [district] court committed plain error or exceptional circumstances exist.'" State v. Pinder, 2005 UT 15, ¶ 45 , 114 P.3d 551 (quoting State v. Nelson-Waggoner, 2004 UT 29, ¶ 16 , 94 P.3d 186 ).

2011We do not consider issues raised " 'for the first time on appeal unless the [district] court committed plain error or exceptional circumstances exist.'" State v. Pinder, 2005 UT 15, ¶ 45 , 114 P.3d 551 (quoting State v. Nelson-Waggoner, 2004 UT 29, ¶ 16 , 94 P.3d 186 ).

22011–2011
State v. Camara green
utahctapp · 2026
1 sentence

2026Wrapping things up, the majority insisted that “the dissent’s reliance on rule 47(l) [was] misplaced,” and it instead said that “[w]hen deciding whether a juror contact with an outsider triggers the rebuttable presumption of prejudice, we do not apply rule 47(l).” Id. ¶ 61. 20220502-CA 25 2026 UT App 5 State v. Camara ¶60 Despite all this, the separate opinion seems to assume that while the Soto majority did not think that rule 47(l) should be used as part of the three-part test, rule 47(l) should be used when assessing the initial question of whether there was an impermissible “contact.” But

12026–2026
Eldridge v. Johndrow green
utah · 2015
2 sentences

2018This leaves us with the reliance inquiry. ¶31 No legitimate reliance interests are at stake : This factor concerns itself with "the extent to which people's reliance on the precedent would create injustice or hardship if it were overturned." Eldridge , 2015 UT 21 , ¶ 35, 345 P.3d 553 .

2018This leaves us with the reliance inquiry. ¶31 No legitimate reliance interests are at stake : This factor concerns itself with "the extent to which people's reliance on the precedent would create injustice or hardship if it were overturned." Eldridge , 2015 UT 21 , ¶ 35, 345 P.3d 553 .

12018–2018
Limb v. Federated Milk Producers Association green
utah · 1969
2 sentences

2006Because we uphold the trial court’s decision on other grounds, the trial court's reliance on rule 37(f) is harmless error. "[A]n appellate court may affirm a judgment, order, or decree appealed from if it is sustainable on any legal ground or theory apparent on the record,’ even though that ground or theory was not identified by the lower court as the basis of its ruling.” Orton v. Carter, 970 P.2d 1254, 1260 (Utah 1998) (quoting Limb v. Federated Milk Producers Ass’n, 23 Utah 2d 222 , 461 P.2d 290 , 293 n. 2 (1969)). .

2006Because we uphold the trial court’s decision on other grounds, the trial court's reliance on rule 37(f) is harmless error. "[A]n appellate court may affirm a judgment, order, or decree appealed from if it is sustainable on any legal ground or theory apparent on the record,’ even though that ground or theory was not identified by the lower court as the basis of its ruling.” Orton v. Carter, 970 P.2d 1254, 1260 (Utah 1998) (quoting Limb v. Federated Milk Producers Ass’n, 23 Utah 2d 222 , 461 P.2d 290 , 293 n. 2 (1969)). .

12006–2006
Baggs v. Anderson green
utah · 1974
2 sentences

1997As we stated in Baggs v. Anderson, 528 P.2d 141 (Utah 1974), the reliance requirement “is not satisfied by the mere fact that he indulged in the pleasant and euphoric assumption that he would not have to meet his obligations and that he bought a more expensive car and moved to a more expensive apartment.” Id. at 144 .

1997As we stated in Baggs v. Anderson, 528 P.2d 141 (Utah 1974), the reliance requirement “is not satisfied by the mere fact that he indulged in the pleasant and euphoric assumption that he would not have to meet his obligations and that he bought a more expensive car and moved to a more expensive apartment.” Id. at 144 .

11997–1997
S & F SUPPLY COMPANY v. Hunter green
utah · 1974
2 sentences

1996They argue (i) that in S & F Supply Co. v. Hunter, 527 P.2d 217 (Utah 1974), this court interpreted the pre-1990 *564 version of section 61-1-22 as requiring purchaser reliance and the legislature manifested its intent to adopt S & F Supply 's interpretation when it amended section 61-1-22 in 1990 but left intact the portion of the statute upon which the S & F Supply court relied in inferring a reliance requirement; and alternatively (ii) that section 61-1-22's express private cause of action for violation of section 61-1-1(2) should be interpreted as including the same elements as the federal

1996They argue (i) that in S & F Supply Co. v. Hunter, 527 P.2d 217 (Utah 1974), this court interpreted the pre- 1990 version of section 61-1-22 as requiring purchaser reliance and the legislature manifested its intent to adopt S & F Supply’s interpretation when it amended section 61-1-22 in 1990 but left intact the portion of the statute upon which the S & F Supply court relied in inferring a reliance requirement; and alternatively (ii) that section 61-1-22’s express private cause of action for violation of section 61-1-1(2) should be interpreted as including the same elements as the federal impl

11996–1996
Basic Inc. v. Levinson green
scotus · 1988
2 sentences

1996In Basic Inc., the United States Supreme Court noted, "Reliance provides the requisite causal connection between a defendant's misrepresentation and a plaintiff's injury." Id.

1996In Basic Inc., the United States Supreme Court noted, “Reliance provides the requisite causal connection between a defendant’s misrepresentation and a plaintifPs injury.” Id.

11996–1996
Price-Orem Investment Co. v. Rollins, Brown & Gunnell, Inc. green
utah · 1986
1 sentence

1995Second, we determine whether “second party” Calder “had a pecuniary interest in the transaction,” id.

11995–1995

Where else courts name it

CA 75 (1964–2026) NY 30 (1906–2025) IL 26 (1977–2024) PA 23 (1980–2025) TX 18 (1978–2022) WA 18 (1986–2026) AL 16 (1991–2025) CT 15 (1995–2024) MA 14 (1960–2025) MD 14 (1969–2024) FL 14 (1973–2020) NJ 12 (1981–2022) WI 11 (1985–2025) MI 9 (1978–2024) UT 8 (1995–2026) GA 8 (1978–2026) OH 8 (1966–2018) AZ 7 (1973–2020) DC 7 (1979–2022) LA 7 (1985–2017) VT 6 (1967–2018) NM 6 (2000–2021) NC 6 (1986–2020) ID 6 (1979–2021) NE 5 (1988–2024) AK 5 (1976–1989) OR 5 (2001–2012) MN 5 (1971–2017) CO 5 (1994–2026) TN 4 (1995–2014) NV 4 (1957–2014) IA 4 (2006–2018) WV 4 (1980–2017) RI 4 (2002–2023) IN 4 (1978–2023) VA 4 (2008–2018) MO 3 (1966–2017) KS 3 (1972–2008) MS 2 (2007–2007) HI 2 (1996–2017) KY 2 (2011–2026) SC 2 (2000–2011) SD 2 (2004–2009) VI 2 (2009–2011) ME 2 (2007–2012) ND 2 (1976–2018) NH 2 (1997–2005)

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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