August 22, 2019

Tenth Circuit: Utah Supreme Court’s Dismissal on Laches Grounds Constitutes a Decision on the Merits

The Tenth Circuit issued its opinion in Fundamentalist Church of Jesus Christ of Latter-Day Saints v. Horne on Monday, November 5, 2012.

The Fundamentalist Church of Jesus Christ of Latter-Day Saints (“FLDS”)  filed a complaint in federal district court seeking declaratory and injunctive relief regarding the Utah probate court’s reformation and administration of a religious charitable trust (“Trust”). FLDS also moved for a temporary restraining order and a preliminary injunction against the probate court’s administration of the trust. This federal suit was stayed pending settlement negotiations.

While the federal case was pending, FLDS filed a petition for extraordinary writ with the Utah Supreme Court raising substantially the same claims as the federal complaint. The Utah Supreme Court dismissed the petition finding that FLDS’s claims regarding the trust were barred by the equitable doctrine of laches. FLDS then renewed its motion for temporary restraining order and preliminary injunction in federal court. The district court entered a temporary restraining order and also granted FLDS’s motion for a preliminary injunction, finding there was no basis for laches. The district court also found that the Utah Supreme Court’s finding of laches was not a judgment on the merits for res judicata purposes.

Defendants appealed the district court’s order granting FLDS a preliminary injunction. The Tenth Circuit certified the following question to the Utah Supreme Court:

Under Utah preclusion law, is the Utah Supreme Court’s discretionary review of a petition for extraordinary writ and subsequent dismissal on laches grounds a decision “on the merits” when it is accompanied by a written opinion, such that later adjudication of the same claim is barred?

In its answer to the Tenth Circuit’s certified question, the Utah Supreme Court concluded that such a decision is a decision on the merits for res judicata purposes that would preclude a subsequent action on the same claims between the same parties.

Having received the Utah Supreme Court’s answer, the Tenth Circuit concluded that FLDS was precluded from pursuing its claims in federal court.  The district court erred in granting a preliminary injunction, and specifically erred in holding that the Utah Supreme Court’s finding of laches was not a judgment on the merits for res judicata purposes.

Accordingly, the Tenth Circuit VACATED the district court’s grant of preliminary injunction and REMANDED with directions to dismiss the claims filed by the FLDS Association as barred by res judicata.

Print Friendly, PDF & Email

Speak Your Mind

*