7 Utah opinions name it 2 courts 1950–2026 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.
| Case | Followed | Cited |
|---|---|---|
Farmers Texas County Mutual Insurance Co. v. Romogreen1 sentence2026Co. v. Romo, 250 S.W.3d 527, 539 (Tex. App. 2008); see also Caudill v. Commonwealth, 120 S.W.3d 635 , 676 n.4 (Ky. 2003) (concluding that jury instructions “conformed to the obviously intended meaning of [a] statute” when the enacted statutory “language [made] no sense and [was] an obvious typographical error”); Stanton v. Frankel Bros. | 1 | 1 |
Caudill v. Commonwealthgreen1 sentence2026Co. v. Romo, 250 S.W.3d 527, 539 (Tex. App. 2008); see also Caudill v. Commonwealth, 120 S.W.3d 635 , 676 n.4 (Ky. 2003) (concluding that jury instructions “conformed to the obviously intended meaning of [a] statute” when the enacted statutory “language [made] no sense and [was] an obvious typographical error”); Stanton v. Frankel Bros. | 1 | 1 |
United States v. Walter Coatoamgreen1 sentence2026See United States v. Coatoam, 245 F.3d 553, 559 (6th Cir. 2001) (stating that the “very language of the statute . . . compels our conclusion that Congress intended . . . to cross-reference readers to a related statute” instead of the 20230738-CA 9 2026 UT App 1 State v. Allred statute indicated in the text); King v. Housing Auth., 670 F.2d 952 , 954 n.4 (11th Cir. 1982) (concluding that a cross-referenced subsection in the Code of Federal Regulations was a typographical error because the referenced section did not concern the material in the referring regulation). ¶20 That the cross-reference | 1 | 1 |
State v. Allredgreen1 sentence2026See United States v. Coatoam, 245 F.3d 553, 559 (6th Cir. 2001) (stating that the “very language of the statute . . . compels our conclusion that Congress intended . . . to cross-reference readers to a related statute” instead of the 20230738-CA 9 2026 UT App 1 State v. Allred statute indicated in the text); King v. Housing Auth., 670 F.2d 952 , 954 n.4 (11th Cir. 1982) (concluding that a cross-referenced subsection in the Code of Federal Regulations was a typographical error because the referenced section did not concern the material in the referring regulation). ¶20 That the cross-reference | 1 | 1 |
State v. Rosariogreen2 sentences2013See, e.g., State v. Valle-Flores, 2005 UT App 290, ¶¶ 2-5 , 117 P.3d 1069 (holding that a warrant to search 626 Pueblo Street was supported by probable cause despite the supporting affidavit's reference to both 624 Pueblo Street and 626 Pueblo Street); State v. Wallace, 2002 UT App 295, ¶¶ 24-26 , 55 P.3d 1147 (holding that a warrant to obtain a blood sample was valid despite a reference to a urine sample in the addendum to the affidavit because the "minor inconsistency" did "not seriously undermine the information underlying the probable cause determination"); United States v. Snyder, 471 Fed 2013See, e.g., State v. Valle-Flores, 2005 UT App 290, ¶¶ 2-5 , 117 P.3d 1069 (holding that a warrant to search 626 Pueblo Street was supported by probable cause despite the supporting affidavit's reference to both 624 Pueblo Street and 626 Pueblo Street); State v. Wallace, 2002 UT App 295, ¶¶ 24-26 , 55 P.3d 1147 (holding that a warrant to obtain a blood sample was valid despite a reference to a urine sample in the addendum to the affidavit because the "minor inconsistency" did "not seriously undermine the information underlying the probable cause determination"); United States v. Snyder, 471 Fed | 1 | 1 |
State v. Valle-Floresgreen2 sentences2013See, e.g., State v. Valle-Flores, 2005 UT App 290, ¶¶ 2-5 , 117 P.3d 1069 (holding that a warrant to search 626 Pueblo Street was supported by probable cause despite the supporting affidavit's reference to both 624 Pueblo Street and 626 Pueblo Street); State v. Wallace, 2002 UT App 295, ¶¶ 24-26 , 55 P.3d 1147 (holding that a warrant to obtain a blood sample was valid despite a reference to a urine sample in the addendum to the affidavit because the "minor inconsistency" did "not seriously undermine the information underlying the probable cause determination"); United States v. Snyder, 471 Fed 2013See, e.g., State v. Valle-Flores, 2005 UT App 290, ¶¶ 2-5 , 117 P.3d 1069 (holding that a warrant to search 626 Pueblo Street was supported by probable cause despite the supporting affidavit's reference to both 624 Pueblo Street and 626 Pueblo Street); State v. Wallace, 2002 UT App 295, ¶¶ 24-26 , 55 P.3d 1147 (holding that a warrant to obtain a blood sample was valid despite a reference to a urine sample in the addendum to the affidavit because the "minor inconsistency" did "not seriously undermine the information underlying the probable cause determination"); United States v. Snyder, 471 Fed | 1 | 1 |
United States v. Maxwellgreen1 sentence2013See, e.g., State v. Valle-Flores, 2005 UT App 290, ¶¶ 2-5 , 117 P.3d 1069 (holding that a warrant to search 626 Pueblo Street was supported by probable cause despite the supporting affidavit's reference to both 624 Pueblo Street and 626 Pueblo Street); State v. Wallace, 2002 UT App 295, ¶¶ 24-26 , 55 P.3d 1147 (holding that a warrant to obtain a blood sample was valid despite a reference to a urine sample in the addendum to the affidavit because the "minor inconsistency" did "not seriously undermine the information underlying the probable cause determination"); United States v. Snyder, 471 Fed | 1 | 1 |
Greenstreet v. Stategreen2 sentences2013But see Stroud v. Commonwealth, 295 Ky. 694 , 175 S.W.2d 368, 369 (1948) (holding that an affidavit did not provide probable cause sufficient to validate a warrant where the affidavit stated an incorrect date uncontra-dicted by any other specific fact in the affidavit); Greenstreet v. State, 392 Md. 652 , 898 A.2d 961, 973-74 (2006) (same). {16 We conclude that the affidavit here contained a substantial basis for the trial court to determine that the reference to September 26 was a typographical error and that the affidavit, read as a whole, presented a fair probability that evidence of child 2013But see Stroud v. Commonwealth, 295 Ky. 694 , 175 S.W.2d 368, 369 (1948) (holding that an affidavit did not provide probable cause sufficient to validate a warrant where the affidavit stated an incorrect date uncontra-dicted by any other specific fact in the affidavit); Greenstreet v. State, 392 Md. 652 , 898 A.2d 961, 973-74 (2006) (same). {16 We conclude that the affidavit here contained a substantial basis for the trial court to determine that the reference to September 26 was a typographical error and that the affidavit, read as a whole, presented a fair probability that evidence of child | 1 | 1 |
State v. Marquardtgreen1 sentence2013See, e.g., State v. Valle-Flores, 2005 UT App 290, ¶¶ 2-5 , 117 P.3d 1069 (holding that a warrant to search 626 Pueblo Street was supported by probable cause despite the supporting affidavit's reference to both 624 Pueblo Street and 626 Pueblo Street); State v. Wallace, 2002 UT App 295, ¶¶ 24-26 , 55 P.3d 1147 (holding that a warrant to obtain a blood sample was valid despite a reference to a urine sample in the addendum to the affidavit because the "minor inconsistency" did "not seriously undermine the information underlying the probable cause determination"); United States v. Snyder, 471 Fed | 1 | 1 |
State v. Whitegreen1 sentence2013See, e.g., State v. Valle-Flores, 2005 UT App 290, ¶¶ 2-5 , 117 P.3d 1069 (holding that a warrant to search 626 Pueblo Street was supported by probable cause despite the supporting affidavit's reference to both 624 Pueblo Street and 626 Pueblo Street); State v. Wallace, 2002 UT App 295, ¶¶ 24-26 , 55 P.3d 1147 (holding that a warrant to obtain a blood sample was valid despite a reference to a urine sample in the addendum to the affidavit because the "minor inconsistency" did "not seriously undermine the information underlying the probable cause determination"); United States v. Snyder, 471 Fed | 1 | 1 |
United States v. Johnny Lee Snyder, Jr.green1 sentence2013See, e.g., State v. Valle-Flores, 2005 UT App 290, ¶¶ 2-5 , 117 P.3d 1069 (holding that a warrant to search 626 Pueblo Street was supported by probable cause despite the supporting affidavit's reference to both 624 Pueblo Street and 626 Pueblo Street); State v. Wallace, 2002 UT App 295, ¶¶ 24-26 , 55 P.3d 1147 (holding that a warrant to obtain a blood sample was valid despite a reference to a urine sample in the addendum to the affidavit because the "minor inconsistency" did "not seriously undermine the information underlying the probable cause determination"); United States v. Snyder, 471 Fed | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
Stroud v. Commonwealthgreen2 sentences2013But see Stroud v. Commonwealth, 295 Ky. 694 , 175 S.W.2d 368, 369 (1948) (holding that an affidavit did not provide probable cause sufficient to validate a warrant where the affidavit stated an incorrect date uncontra-dicted by any other specific fact in the affidavit); Greenstreet v. State, 392 Md. 652 , 898 A.2d 961, 973-74 (2006) (same). {16 We conclude that the affidavit here contained a substantial basis for the trial court to determine that the reference to September 26 was a typographical error and that the affidavit, read as a whole, presented a fair probability that evidence of child 2013But see Stroud v. Commonwealth, 295 Ky. 694 , 175 S.W.2d 368, 369 (1948) (holding that an affidavit did not provide probable cause sufficient to validate a warrant where the affidavit stated an incorrect date uncontra-dicted by any other specific fact in the affidavit); Greenstreet v. State, 392 Md. 652 , 898 A.2d 961, 973-74 (2006) (same). {16 We conclude that the affidavit here contained a substantial basis for the trial court to determine that the reference to September 26 was a typographical error and that the affidavit, read as a whole, presented a fair probability that evidence of child | 1 | 1 |
| Case | Cited | Years |
|---|---|---|
Jimmie Mae King v. The Housing Authority of the City of Huntsville, Alabama a Corporation
green
1 sentence2026See United States v. Coatoam, 245 F.3d 553, 559 (6th Cir. 2001) (stating that the “very language of the statute . . . compels our conclusion that Congress intended . . . to cross-reference readers to a related statute” instead of the 20230738-CA 9 2026 UT App 1 State v. Allred statute indicated in the text); King v. Housing Auth., 670 F.2d 952 , 954 n.4 (11th Cir. 1982) (concluding that a cross-referenced subsection in the Code of Federal Regulations was a typographical error because the referenced section did not concern the material in the referring regulation). ¶20 That the cross-reference | 1 | 2026–2026 |
Bradsen v. Shellpoint Mortgage Services
green
1 sentence2022The same is not true, however, of the words ‘beneficiary’ and ‘individually.’” Id. 20200244-CA 17 2022 UT App 10 Bradsen v. Shellpoint ¶42 In light of this precedent, we have no trouble concluding that the error in the 2013 Assignment is not a minor typographical or clerical error that can be corrected by the filing of an affidavit or corrected deed under section 57-3-106(9). | 1 | 2022–2022 |
Equine Holdings v. Auburn Woods
green
1 sentence2021Specifically, the legal description: (1) uses as its starting reference “the Northeast quarter corner” of a section, a term the parties here agree is meaningless in the Public Land 20181022-CA 5 2021 UT App 14 Equine Holdings v. Auburn Woods Survey System; (2) states that the point of beginning is “a point South 66°16’38” West 1943.76 feet” from the aforementioned “Northeast quarter corner,” a direction and distance that the parties agree is materially erroneous, because the true starting point was apparently meant to be “a point South 66°49’59” West, 1933.88 feet, from the Northeast corner”; | 1 | 2021–2021 |
Frito-Lay v. Utah Labor Commission
green
2 sentences2021Pursuant to Utah Code section 34A-2-420(1), the Commission is granted “continuing” jurisdiction over each case before it and “may from time to time modify or change a former finding or order of the commission.” Furthermore, our Supreme Court has held that “the power of the Commission as to its continuing jurisdiction . . . is extended to the right to rescind, alter, or amend orders, decisions, or awards on good cause appearing therefor.” Frito-Lay v. Utah Labor Comm'n, 2009 UT 71, ¶ 25 , 222 P.3d 55 (quotation simplified). 2021Pursuant to Utah Code section 34A-2-420(1), the Commission is granted “continuing” jurisdiction over each case before it and “may from time to time modify or change a former finding or order of the commission.” Furthermore, our Supreme Court has held that “the power of the Commission as to its continuing jurisdiction . . . is extended to the right to rescind, alter, or amend orders, decisions, or awards on good cause appearing therefor.” Frito-Lay v. Utah Labor Comm'n, 2009 UT 71, ¶ 25 , 222 P.3d 55 (quotation simplified). | 1 | 2021–2021 |
State v. Galindo
green
1 sentence2019We therefore do not consider it in reaching our decision on his first ineffective assistance claim. 20180116-CA 6 2019 UT App 171 State v. Galindo ¶12 Galindo also believes that Dr. Wilkinson’s report concluded that Galindo “was ‘not able to consult with his attorney and participate in the proceeding against him with a reasonable degree of rational understanding.’” (Emphasis added.) But we agree with the State that the insertion of the word “not” in that sentence of the report is “most reasonably read as a typographical error” in light of its context and the report as a whole. | 1 | 2019–2019 |
State v. Wallace
green
2 sentences2013See, e.g., State v. Valle-Flores, 2005 UT App 290, ¶¶ 2-5 , 117 P.3d 1069 (holding that a warrant to search 626 Pueblo Street was supported by probable cause despite the supporting affidavit's reference to both 624 Pueblo Street and 626 Pueblo Street); State v. Wallace, 2002 UT App 295, ¶¶ 24-26 , 55 P.3d 1147 (holding that a warrant to obtain a blood sample was valid despite a reference to a urine sample in the addendum to the affidavit because the "minor inconsistency" did "not seriously undermine the information underlying the probable cause determination"); United States v. Snyder, 471 Fed 2013See, e.g., State v. Valle-Flores, 2005 UT App 290, ¶¶ 2-5 , 117 P.3d 1069 (holding that a warrant to search 626 Pueblo Street was supported by probable cause despite the supporting affidavit's reference to both 624 Pueblo Street and 626 Pueblo Street); State v. Wallace, 2002 UT App 295, ¶¶ 24-26 , 55 P.3d 1147 (holding that a warrant to obtain a blood sample was valid despite a reference to a urine sample in the addendum to the affidavit because the "minor inconsistency" did "not seriously undermine the information underlying the probable cause determination"); United States v. Snyder, 471 Fed | 1 | 2013–2013 |
George v. Fritsch Loan & Trust Co.
green
2 sentences1950In Nordfors v. Knight et ux, 90 Utah 114 , 60 P. 2d 1115 , at page 1116, this court discusses the rule applicable to reformation, and at page 116 quotes from the case of George v. Fritsch Loan & Trust Co., 69 Utah 460 , 256 P. 400, 403 , as follows [I have taken the liberty of correcting a typographical error in the Utah Reports by inserting the italicized word “of” for “to” in the quotation.] : “The law is well settled in this and in other jurisdictions that a written contract will be reformed to express the agreement of the parties where the proof of the mistake is clear, definite, and convi 1950In Nordfors v. Knight et ux, 90 Utah 114 , 60 P. 2d 1115 , at page 1116, this court discusses the rule applicable to reformation, and at page 116 quotes from the case of George v. Fritsch Loan & Trust Co., 69 Utah 460 , 256 P. 400, 403 , as follows [I have taken the liberty of correcting a typographical error in the Utah Reports by inserting the italicized word “of” for “to” in the quotation.] : “The law is well settled in this and in other jurisdictions that a written contract will be reformed to express the agreement of the parties where the proof of the mistake is clear, definite, and convi | 1 | 1950–1950 |
Nordfors v. Knight Et Ux.
green
2 sentences1950In Nordfors v. Knight et ux, 90 Utah 114 , 60 P. 2d 1115 , at page 1116, this court discusses the rule applicable to reformation, and at page 116 quotes from the case of George v. Fritsch Loan & Trust Co., 69 Utah 460 , 256 P. 400, 403 , as follows [I have taken the liberty of correcting a typographical error in the Utah Reports by inserting the italicized word “of” for “to” in the quotation.] : “The law is well settled in this and in other jurisdictions that a written contract will be reformed to express the agreement of the parties where the proof of the mistake is clear, definite, and convi 1950In Nordfors v. Knight et ux, 90 Utah 114 , 60 P. 2d 1115 , at page 1116, this court discusses the rule applicable to reformation, and at page 116 quotes from the case of George v. Fritsch Loan & Trust Co., 69 Utah 460 , 256 P. 400, 403 , as follows [I have taken the liberty of correcting a typographical error in the Utah Reports by inserting the italicized word “of” for “to” in the quotation.] : “The law is well settled in this and in other jurisdictions that a written contract will be reformed to express the agreement of the parties where the proof of the mistake is clear, definite, and convi | 1 | 1950–1950 |
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.