Supreme Court Reverses “Bridgegate” Convictions

MICHAEL C. DORF

Cornell law professor Michael C. Dorf comments on last week’s decision by the U.S. Supreme Court reversing the convictions of two New Jersey officials for their role in the so-called “Bridgegate” scandal of 2013. Although the Court made clear that the underlying conduct was dangerous and wrong, its holding reversing the convictions may effectively permit corrupt bullies to continue to exercise political power, due in part to inadequate responses from other political actors.

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Taylor v. University of Utah

Citation: 2020 UT 21

Opinion Date: May 8, 2020

Judge: Himonas

Areas of Law: Medical Malpractice, Personal Injury

In this medical malpractice action, the Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court excluding Plaintiffs' proximate cause expert's testimony, holding that the district court did not err. Plaintiffs brought suit against the University of Utah Hospital alleging that the Hospital's treatment of their daughter's baclofen withdrawal caused the daughter's permanent injuries. The Hospital filed a motion in limine to exclude the testimony of Plaintiffs' causation expert, arguing that the testimony should be barred under Utah R. Evid. 702 because the expert's opinion was not based upon sufficient facts or data. The district court agreed and excluded the testimony. At issue on appeal was whether the threshold showing that the principles or methods underlying in the expert's testimony were based upon sufficient facts or data where the method - logical deduction - was based upon broad and attenuated facts. The Supreme Court held that the showing was not present in this case, and therefore, the district court properly excluded the expert testimony on proximate cause.

Harrison v. SPAH Family Ltd.

Citation: 2020 UT 22

Opinion Date: May 8, 2020

Judge: Matthew B. Durrant

Areas of Law: Real Estate & Property Law

The Supreme Court affirmed the judgment of the district court, on summary judgment, ruling that a prescriptive easement had been formed, but held that the court incorrectly instructed the jury regarding the scope of the prescriptive easement and therefore remanded the case for a new trial with the correct jury instruction. On summary judgment, the district court determined that Appellees had established a prescriptive easement across the property of Appellants. After a trial for a determination of the scope of that easement, the jury returned a verdict, and the court entered a final judgment. The Supreme Court held (1) on summary judgment, the district court did not err in ruling that a prescriptive easement had formed; (2) the district court did not abuse its discretion in its decisions regarding the admissibility of the parties' respective expert witnesses; but (3) the district court erred in instructing the jury regarding the scope of the prescriptive easement, necessitating a new trial.

SRB Investment Co., Ltd. v. Spencer

Citation: 2020 UT 23

Opinion Date: May 8, 2020

Judge: Matthew B. Durrant

Areas of Law: Real Estate & Property Law

The Supreme Court reversed the judgment of the district court determining that SRB Investment Company had established a prescriptive easement but prohibiting SRB from using the easement for any reason other than to access the SRB property for the purposes of ranching or farming, holding that the court improperly focused on the purposes for which SRB's land would be used rather than on the purpose for which the relevant portion of the servant estate would be used. SRB sought access to its property through a prescriptive easement crossing land owned by the Spencer family. The district court determined that SRB had acquired a prescriptive easement across the Spencer property and then limited the scope of the easement. The Supreme Court reversed, holding that the district court erred in defining the scope of the easement based on how SRB used its own property during the prescriptive period and instead should have defined the scope of the easement based on how SRB used the Spencer's property during that period.