Chandler test (Utah) · Go Syfert
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Chandler test in Utah

7 Utah opinions name it 2 courts 2002–2024 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 (2)

CaseFollowedCited
Chandler v. Blue Cross Blue Shield of Utahgreen
utah · 1992 · cited in 4 Utah opinions naming this issue, 2002–2024
2 sentences

2022Had the court applied the Chandler test, the result would have been the same. ¶26 Under Chandler, “waiver of a right of arbitration must be based on both a finding of participation in litigation to a point inconsistent with the intent to arbitrate and a finding of prejudice.” Id. (emphasis added).

2022Had the court applied the Chandler test, the result would have been the same. ¶26 Under Chandler, “waiver of a right of arbitration must be based on both a finding of participation in litigation to a point inconsistent with the intent to arbitrate and a finding of prejudice.” Id. (emphasis added).

24
Central Florida Investments, Inc. v. Parkwest Associatesgreen
utah · 2002 · cited in 4 Utah opinions naming this issue, 2004–2021
2 sentences

2021“The party claiming waiver has the burden of establishing substantial participation and prejudice.” Id. ¶12 Before we address the two prongs of the Chandler test, we must first resolve the parties’ dispute over the proper standard of review.

2021“The party claiming waiver has the burden of establishing substantial participation and prejudice.” Id. ¶12 Before we address the two prongs of the Chandler test, we must first resolve the parties’ dispute over the proper standard of review.

14

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 (7)

CaseCitedYears
Turpin v. Valley Obstetrics and Gynecology green
utahctapp · 2021
2 sentences

2022Not only did the Livingstons neglect to provide any evidence to the district court to demonstrate that they incurred “significant expenses” defending against the removal sufficient to establish prejudice under the Chandler standard, see Turpin, 2021 UT App 12, ¶ 28 , they conceded in oral argument before this court that the federal court awarded them the attorney fees they incurred when it rejected the removal as improper.

2022Not only did the Livingstons neglect to provide any evidence to the district court to demonstrate that they incurred “significant expenses” defending against the removal sufficient to establish prejudice under the Chandler standard, see Turpin, 2021 UT App 12, ¶ 28 , they conceded in oral argument before this court that the federal court awarded them the attorney fees they incurred when it rejected the removal as improper.

22021–2022
Hardman v. Hardman green
utahctapp · 2024
2 sentences

2024As we did in Turpin and Livingston, because none of the parties has argued that prejudice is no longer an element of the Chandler waiver test, and because we do not reach the prejudice question anyway, we assume for purposes of our review that the prejudice prong still applies. 20220609-CA 7 2024 UT App 115 Hardman v. Hardman ¶12 Before we address the two parts of the Chandler test, we must first resolve the parties’ dispute over the proper standard of review.

2024As we did in Turpin and Livingston, because none of the parties has argued that prejudice is no longer an element of the Chandler waiver test, and because we do not reach the prejudice question anyway, we assume for purposes of our review that the prejudice prong still applies. 20220609-CA 7 2024 UT App 115 Hardman v. Hardman ¶12 Before we address the two parts of the Chandler test, we must first resolve the parties’ dispute over the proper standard of review.

12024–2024
Livingston v. Finco Holdings green
utahctapp · 2022
2 sentences

2022Accordingly, we assume for purposes of our review in this case that the prejudice prong still applies. 20200200-CA 13 2022 UT App 71 Livingston v. Finco Holdings did not show that Lender Defendants’ delay in seeking arbitration prejudiced them.

2022The Livingstons claim they suffered prejudice because they incurred “substantial litigation expense” and several of their claims were 20200200-CA 14 2022 UT App 71 Livingston v. Finco Holdings dismissed.

12022–2022
Mounteer Enters., Inc. v. Homeowners Ass'n for the Colony at White Pine Canyon green
utah · 2018
2 sentences

2021Id. ¶¶ 9–10, 31–34.

2021Id. ¶¶ 9–10, 31–34.

12021–2021
ASC Utah, Inc. v. Wolf Mountain Resorts, L.C. green
utah · 2010
2 sentences

2021There, the court stated, for the first time in the Chandler context, that “when a district court denies a motion to compel arbitration based on documentary evidence alone, it is a legal conclusion that is reviewed for correctness.” ASC Utah, 2010 UT 65, ¶ 11 . ¶16 Turpin invites us to overlook this statement, arguing that “the standard of review in ASC Utah does not apply here” because the ASC Utah court decided only whether the Chandler test applied in that case and did not evaluate whether the evidence supported the district court’s waiver determination.

2021There, the court stated, for the first time in the Chandler context, that “when a district court denies a motion to compel arbitration based on documentary evidence alone, it is a legal conclusion that is reviewed for correctness.” ASC Utah, 2010 UT 65, ¶ 11 . ¶16 Turpin invites us to overlook this statement, arguing that “the standard of review in ASC Utah does not apply here” because the ASC Utah court decided only whether the Chandler test applied in that case and did not evaluate whether the evidence supported the district court’s waiver determination.

12021–2021
Baker v. Stevens green
utah · 2005
2 sentences

2021See, e.g., Chandler, 833 P.2d at 360 ; Central Fla. Invs. 2002 UT 3, ¶ 28 ; Baker v. Stevens, 2005 UT 32 , ¶¶ 13–15, 114 P.3d 580 ; Smile Inc. Asia Pte.

2021See, e.g., Chandler, 833 P.2d at 360 ; Central Fla. Invs. 2002 UT 3, ¶ 28 ; Baker v. Stevens, 2005 UT 32 , ¶¶ 13–15, 114 P.3d 580 ; Smile Inc. Asia Pte.

12021–2021
EDUCATORS MUT. INS. ASS'N v. Evans green
utahctapp · 2011
2 sentences

2021Id.

2021Id.

12021–2021

Where else courts name it

GA 10 (1992–2016) UT 7 (2002–2024) MS 6 (1994–2022) FL 6 (1994–2009) OH 4 (2000–2016) NY 4 (1985–2021) VA 3 (2014–2020) IN 3 (1995–1996) CA 2 (2014–2014) OK 2 (1981–2004) VT 2 (2015–2016) WA 2 (2001–2001) ID 2 (2022–2022)

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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