Background - Parents litigated divorce; Father sought termination of Mother's parental rights in juvenile court; juvenile court retained jurisdiction over child-welfare and related custody/support matters and denied Father's petition, awarded Mother custody, and ordered Father to pay Mother's legal fees. - Juvenile court awarded attorney fees but did not reduce the award to a district-court judgment before Father and Stepmother prematurely appealed to the court of appeals; that court issued an opinion affirming most of the juvenile-court orders. - On remand the juvenile court completed child-welfare proceedings and terminated its jurisdiction, referring the unresolved attorney-fees order to the district court for entry of judgment; the district court entered a judgment for $180,780.47 in Mother's favor (April 6, 2015). - Father filed documents associated with a Rule 59 motion; the formal Rule 59 motion was electronically docketed minutes after midnight on April 21, 2015 — one day late — though a supporting memorandum was filed just before midnight on April 20. - The district court nevertheless considered and denied the Rule 59 motion; Father appealed, and this Court sua sponte examined whether the Rule 59 filing was timely under the e-filing rules and Utah R. Civ. P. 6(b)(2). - The Supreme Court held Father’s Rule 59 motion was untimely under the court’s e-filing timestamp rules, the timely memorandum could not substitute for a timely Rule 59 motion, and Rule 6(b)(2) prohibited the district court from extending time; therefore the appeal was untimely and the Court lacked jurisdiction. Mother was awarded attorney fees and costs on appeal and the case was remanded to the district court to set those fees. ### Issues | Issue | Father’s Argument | Mother’s Argument | Held | |---|---:|---|---| | Whether Father timely filed a Rule 59(e) motion to alter or amend | Filing was timely because supporting memorandum was filed before midnight and should confer jurisdiction | E-filing timestamp controls; Rule 59 motion was filed after deadline and is untimely | Motion was untimely under the court’s e-filing timestamp; memorandum cannot substitute; motion barred by Rule 6(b)(2) | | Whether a supporting memorandum can substitute for a timely Rule 59 motion | The timely memorandum substantively requested relief and should be treated as the motion | Rules distinguish motions from memoranda; substance and form must meet Rule 7 requirements | Memorandum insufficient in form and substance to substitute for a Rule 59 motion; timeliness requires a motion filing | | Whether the district court could consider an untimely Rule 59 motion | District courts have inherent discretion and may consider untimely postjudgment motions | Rule 6(b)(2) forbids extending time for Rule 59 motions; court had no authority to accept late motion | Rule 6(b)(2) removes discretion; district court lacked authority and should have denied the untimely motion | | Whether this Court has jurisdiction to hear the appeal | Father argued the district court’s consideration preserved issues and tolled appeal deadlines | Mother argued appeal was untimely and jurisdictional defects are non-waivable | Appeal was untimely; this Court lacks jurisdiction to reach merits; April 6 judgment remains final | ### Key Cases Cited DFI Props. LLC v. GR 2 Enters. LLC, 242 P.3d 781 (Utah 2010) (holding attorney-fee awards not reduced to a specific judgment are not final for appeal) Sanpete Am., LLC v. Willardsen, 269 P.3d 118 (Utah 2011) (untimely Rule 59 motion cannot be granted; only option is denial) Gillett v. Price, 135 P.3d 861 (Utah 2006) (abrogating practice of treating postjudgment "motions to reconsider" as tolling appeal periods) Burdick v. Horner Townsend & Kent, Inc., 345 P.3d 531 (Utah 2015) (discussing discretion to consider motions when final judgment not yet entered; distinguishes cases where jurisdiction remains) Workers Comp. Fund v. Argonaut Ins. Co., 266 P.3d 792 (Utah 2011) (timeliness of appeal is jurisdictional and requires dismissal if appeal not timely perfected) In re E.S. & N.S., 310 P.3d 744 (Utah Ct. App. 2013) (court of appeals opinion arising from juvenile-court orders; treated as final where certiorari window lapsed)